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Review of Western Sydney Airport Draft Environmental Impact Statement 26 November 2015

Document information

Client: WSROC Title: Review of Western Sydney Airport Draft Environmental Impact Statement Document No: 2269591A-ENV-REP-001 RevFINAL Date: 26 November 2015

Rev Date Details

DRAFT 20/11/2015 First draft

FINAL 25/11/2015 Final to WSROC

Author, Reviewer and Approver details

Prepared by: Emma Dean Date: 25/11/2015 Signature:

Reviewed by: Paul Greenhalgh Date: 25/11/2015 Signature:

Approved by: Paul Greenhalgh Date: 25/11/2015 Signature:

Distribution

WSROC, Parsons Brinckerhoff file, Parsons Brinckerhoff Library

©Parsons Brinckerhoff Australia Pty Limited 2015

Copyright in the drawings, information and data recorded in this document (the information) is the property of Parsons Brinckerhoff. This document and the information are solely for the use of the authorised recipient and this document may not be used, copied or reproduced in whole or part for any purpose other than that for which it was supplied by Parsons Brinckerhoff. Parsons Brinckerhoff makes no representation, undertakes no duty and accepts no responsibility to any third party who may use or rely upon this document or the information.

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WSROC Review of Western Sydney Airport Draft Environmental Impact Statement

Contents Page number

Glossary iv

Executive summary v

1. Introduction 1

1.1 Background 1

2. Approach to peer review 3

2.1 Governance arrangements 3

2.1.1 Role of WSROC 3 2.1.2 Role of the Steering Committee 4

2.2 Methodology 4

2.2.1 Project inception and early tasks 4 2.2.2 Preparation of the consultant briefs and nomination of potential specialists 4 2.2.3 Evaluation and engagement of specialist proposals 5 2.2.4 Scope of the specialist peer reviews 5 2.2.5 Preparation of overarching review report 5

2.3 Draft EIS review team 6

2.4 Limitations 6

2.4.1 Technical reports excluded from review 7

3. Review of the overall draft EIS 9

3.1 Planning and land use statutory approvals context 10

3.1.1 Draft Airport Plan 11

3.2 General observations 12

3.2.1 Airspace planning (Airspace architecture) 12 3.2.2 Short term assessment within the draft Airport Plan 13 3.2.3 High level traffic and transport assessment 13 3.2.4 Uncertainty over longer term development and cumulative impact 14 3.2.5 Lack of State integration 14

3.3 Management and mitigation measures 15

3.4 Consultation activities 15

4. Review of technical reports 17

4.1 Noise 17

4.1.1 Aircraft overflight noise 17 4.1.2 Ground based noise and vibration 22

4.2 Air quality and greenhouse gas 24

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4.2.1 Overall comments on air quality study 24 4.2.2 Stage 1 development 25 4.2.3 Longer term development 26

4.3 Traffic, transport and access 27

4.3.1 Approach 27 4.3.2 Stage 1 development 27 4.3.3 Long term Airport development 28 4.3.4 Key impacts and opportunities 29

4.4 Human health 29

4.4.1 Approach 29 4.4.2 Limitations 30 4.4.3 Components of draft EIS Reviewed 30 4.4.4 1st Stage Airport findings 31 4.4.5 Long term development findings 34 4.4.6 Key impacts and opportunities 34

4.5 Aviation planning 35

4.5.1 Approach 35 4.5.2 Stage 1 development 35 4.5.3 Long term development 36 4.5.4 Key impacts and opportunities 36

4.6 Social and Economic 37

4.6.1 Approach 37 4.6.2 Components of the draft EIS reviewed 38 4.6.3 Stage 1 development 38 4.6.4 Long term development 39 4.6.5 Key impacts and opportunities 40

4.7 Surface water and groundwater 41

4.7.1 Approach 41 4.7.2 Limitations 42 4.7.3 Components of the EIS reviewed 42 4.7.4 Stage 1 airport 43 4.7.5 Long term development 45 4.7.6 Key impacts and opportunities 46

4.8 Greater Blue Mountains 47

4.8.1 Approach 47 4.8.2 Components of draft EIS reviewed 47 4.8.3 Findings 48 4.8.4 Long term development 52

4.9 Biodiversity 53

4.9.1 Stage 1 development review findings 54 4.9.2 Long-term development review findings 54 4.9.3 Key impacts and opportunities 54

5. Conclusions 55

5.1 Key findings 55

6. References 57

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List of tables Page number

Table 2.1 EIS review team 6 Table 3.1 Summary of compliance with EIS guidelines 9 Table 3.2 Summary of activity forecasts 12 Table 4.1 Summary of impacts and opportunities 40 Table 4.2 Compliance of draft Western Sydney Airport EIS with EPBC Act Guidelines 48

List of figures Page number

Figure 1.1 Program of assessment 2 Figure 3.1 Approval process 11

List of appendices Appendix A Aircraft overflight noise (Marshall Day Acoustics) Appendix B Ground-based noise and vibration (WSP | Parsons Brinckerhoff) Appendix C Air quality and greenhouse gas (Katestone Environmental) Appendix D Traffic and Transport (ARUP) Appendix E Human Health (Centre for Health Equity Training Research and Evaluation) Appendix F Aviation planning (ARUP and The Airport Group) Appendix G Social and economic (Hill PDA Consulting) Appendix H Surface water and groundwater (Cardno) Appendix I Biodiversity (EMM)

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Glossary ALC Airport Lessee Company

ANECs Australian Noise Exposure Concept

ANEF Australian Noise Exposure Forecast

APU Auxiliary Power Units

ATM Annual Traffic Movements

DoE Department of Environment (Commonwealth)

EIS Environmental Impact Statement

EPA NSW Environment Protection Authority

EPBC Act Environment Protection and Biodiversity Act 1999 (Commonwealth)

GBMA Greater Blue Mountains Area

GBMWHA Greater Blue Mountains World Heritage Area

GHG Greenhouse Gas

HIA Health Impact Assessment

HRA Health Risk Assessment

INM Integrated Noise Model

KSA Kingsford Smith Airport

LGA Local Government Area

MACROC Macarthur Regional Organisation of Councils

MAP Million Annual Passengers

MDP Major Development Plan

PPB Parts Per Billion

SWRLe South West Rail Link extension

TSC Act Threatened Species Conservation Act 1995 (NSW)

WSROC Western Sydney Regional Organisations of Councils

Western Sydney Airport Western Sydney Airport

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Executive summary The Western Sydney Airport Project The proposed Western Sydney Airport project will be one of the largest and most complex infrastructure projects in Australia. The project is proposed on Commonwealth land known as Badgerys Creek in the Liverpool Local Government Area.

The project as proposed in the draft Environmental Impact Statement (EIS) is intended as a staged development. The draft EIS and its associated ‘Airport Plan’ considers an initial single-runway development capable of handling up to 185,000 aircraft movements (37 million passengers per annum) nominally by around 2050, following which a dual runway is proposed with a total theoretical maximum capacity of 370,000 aircraft movements per year (82 million passengers) assumed to be reached in 2063.

Stage 1 works include a single 3.7 kilometre runway in the north of the site, capable of handling a full range of international and domestic passenger and freight aircraft, a business park, parking and cargo facilities in addition to areas of environmental conservation. The stage 1 draft EIS includes operation of the airport until 2030 when it is anticipated that approximately 10 million passengers and 63,00 aircraft would use the airport annually.

The draft EIS provides a broad assessment of the eventual two-runway development, but acknowledges that given the long time horizon to full development, more detailed assessment will be required to fully understand the impacts of the project at that time. Instead the draft EIS focuses on the assessment of Stage 1.

The draft EIS also recognises that there is currently no operator (or Airport Lessee Company – ALC) nominated for the construction and operation of the airport, and as such the Airport Plan is considered to be a transitional document until an operator is on board and a detailed masterplanning and project development process can commence. Sydney Airports currently has a first right of refusal to be the operator of the airport under an agreement reached as part of the privatisation of Kingsford Smith Airport. This creates significant uncertainties for the draft EIS, which acknowledges that key aspects of the draft EIS are effectively indicative only.

Statutory approvals context Stage 1 of the Western Sydney Airport project is being assessed under the Environment Protection and Biodiversity Act 1999 (EPBC Act) through an Environmental Impact Statement, as all works are proposed on Commonwealth land (EPBC 2014/7391). The draft EIS was released on public exhibition on Monday 19 October and exhibition will close on Friday 18 December 2015.

The draft EIS contains an ‘Airport Plan’ which defines the proposed layout and land uses for Stage 1 and an associated ‘Airspace Architecture and Operation’, which defines operation and flight paths associated with the airport. The Airport Plan must be approved by the Infrastructure Minister under the Commonwealth Airports Act 1996 (Airports Act) prior to the commencement of development. The approval of the Minister for the Environment is a prerequisite of any consent under the Airports Act, and the Minister for the Environment in deciding to approve the EIS would issue conditions of consent to be imposed through the Airports Act consent on the project. Further detail is provided in Section 1.6.1 of the EIS.

This process is untested in Australia, as to date the Airports Act has only ever been used to manage assessment and approvals relating to the expansion of existing federally leased airports. New legislation has

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been granted (the Airports Amendment Act 2015) specifically to deal with the Western Sydney Airport, to accommodate the special circumstances of a greenfield airport with no lease in place.

Future expansion and approval of the airport beyond 2030 would be subject to further planning and assessment under the Airports Act.

The draft EIS peer review WSP | Parsons Brinckerhoff were engaged by Western Sydney Regional Organisation of Councils (WSROC) and Macarthur Regional Organisation of Councils (MACROC) to project manage the Peer Review of the Western Sydney Airport draft EIS.

In this capacity WSP | Parsons Brinckerhoff was required to run a competitive tendering process to engage specialists in key areas of interest to the councils. WSP | Parsons Brinckerhoff reported to WSROC under the direction of a Steering Committee (of officers of the participating councils) to confirm which specialists should be engaged, the Steering Committee provided direction throughout the review process and reviewed draft inputs.

The key issues nominated for peer review (and the specialists engaged) were:

Aviation planning (Arup)

Overflight noise (Marshall Day)

Ground based noise and vibration (WSP | Parsons Brinckerhoff)

Traffic and transport (Arup)

Air quality and greenhouse gas (Katestone)

Human health impacts (CHETRE)

Social and economic (Hill PDA)

Biodiversity (EMM)

Surface water and Groundwater (Cardno)

Impact on Blue Mountains (WSP | Parsons Brinckerhoff)

In its role of project manager, WSP | Parsons Brinckerhoff undertook an overall review of the draft EIS to cover off issues not addressed by the specialists and developed the overarching findings of the peer review.

Key findings General adequacy

The draft EIS was prepared on a very accelerated program, and it is apparent from media coverage to date that there has been significant Federal political pressure to progress the project rapidly. The draft EIS was prepared over a period of approximately 8 months from engagement of EIS consultants to provision of an initial draft for Commonwealth Department of Environment review. By way of comparison the previous EIS for the project prepared in the late 1990s was undertaken over well over two years. We are aware that the period whereby the Department of Environment reviews the adequacy of the draft EIS prior to approving it for public exhibition was similarly compressed. From our review it is apparent that this has resulted in a number of omissions and limitations, which are discussed throughout this report.

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Airport Layout

The draft EIS nominates a preferred airport layout for both the Stage 1 and long term developments, noting that the layouts are indicative only and would be confirmed once an ALC has been appointed. Alternative layouts are presented for both the Stage 1 and long term layouts, however these are all based on a 50/230 degree runway orientation, in other words there has been no consideration of alternative runway orientations – a key determining factor of flight paths. This contrasts with the EIS undertaken in the late 1990s which examines multiple layouts and runway alignments, and gives little visibility of whether the chosen layout, and in particular the runway alignments, achieve the best environmental outcome. Given the time that has lapsed since the previous EIS we would have expected to see a thorough current option-evaluation process to explore alternatives.

Airspace architecture (flight paths)

Chapter 7 of the draft EIS describes the ‘Airspace Architecture and Operation’ of the proposed airport which includes the flight paths for the Stage 1 Scenario (2030), prepared by Air Services Australia on behalf of the Department of Infrastructure. Only one set of flight paths is provided for 2030 in the draft EIS, featuring a ‘merge point’ (a point at which all incoming flights converge) over Blaxland. The concept of merge points is relatively new, and is considered good practice as it allows for incoming flights to minimise thrust and so reduce noise.

The brief of Air Services Australia as outlined in the draft EIS was to develop a set of flight paths that avoids impacts on existing operations at Kingsford Smith at 2030 (although it was acknowledged that this would be impossible in the long term) and to ensure safety of operations. We have a number of concerns in regard to the flight paths presented in the draft EIS:

The draft EIS makes clear that they have not been designed to minimise environmental (and in particular noise) impacts on communities.

They have taken no account of the smaller airports (Camden, Richmond, Bankstown), other than to note that these would be impacted in the long term.

There is no visibility in the draft EIS of how these contours were arrived at, and how they compare to alternatives considered.

The contours are ‘proof of concept’ – in other words they are indicative only, and could be revised by a future ALC without recourse to the EPBC Act. As such there is considerable uncertainty over what actual impacts may eventuate.

We have the following recommendations in this regard:

Greater consideration of alternative options is required, with an additional objective of minimising environmental impacts.

A holistic review of flight paths taking account of all airports in the Sydney metropolitan area should be undertaken. As part of this, options that allow for flight paths at Kingsford Smith to be modified should be considered.

In recognition that a future ALC may modify the flight paths from those presented in the EIS, sensitivity testing should have been presented to demonstrate the changes of noise impacts that would result if flight paths are modified.

The case for a merge point should be further explored, and consideration of alternative merge points should be examined.

Our peer review was limited to an evaluation of the information presented, and did not extend to development of alternative flight paths by our peer review team. As such we cannot comment on whether the

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flight paths nominated may in fact be the best outcome. In other words the key issue is lack of transparency around the nominated flight paths.

Draft EIS places no explicit limits on key impacts

In a number of areas the EIS does not provide assurances that acceptable environmental thresholds will not be breached, and does not set hard limits on environmental impacts. In the case of aircraft noise this is a reflection of the nature in which aircraft noise is managed in Australia, and this is explored further in Section 4.1.1. However the same is also largely true of other aspects of the draft EIS – the mitigation measures are generally not prescriptive, and there is little in the way of hard limits on impacts. This is no doubt in part due to the fact that the ALC has not yet been appointed, and that the Department of Infrastructure is seeking flexibility over management and mitigation. However this creates uncertainty over the likely future impacts.

Uncertainties over the way the approvals process will operate

As noted above, the project is subject to assessment under the EPBC Act, and the Environment Minister’s agreement (and conditions) are a prerequisite of any subsequent approval under the Airports Act. The draft EIS notes that the future development and expansion of the airport will be subject to further assessment and approval under the Airports Act, and that the preparation of a masterplan will be required within five years of the commencement of the project. This would superseded the current Airport Plan, which is described in the draft EIS as a transitional document. In effect it is implied that once the airport is leased, all future approvals would be under the Airports Act.

What is less clear is:

What the potential triggers would be for further referrals and potentially approvals under the EPBC Act.

What further assessment and approval would be required for the construction and operation of Stage 1 (beyond the current EIS and associated Airport Plan approval) once an ALC is appointed and more is known about the actual airport layout and operations.

What limitations any EPBC Act approval will place on the airport

What level of community and stakeholder engagement will be accommodated in the process going forward.

We would like to have seen greater clarity in this regard.

Key issues raised by specialists

Table ES.1 identified the key issues raised by the specialists for each environmental issue reviewed.

Table ES.1 Summary of key issues raised

Environmental issue Key issues raised

Noise (aircraft overflight) Assessment based on 2030 scenario which reflects early stage of airport operation only

Uncertainty around actual flight paths

Proposed mitigation measures are generic due to uncertainty of flight paths

Outline of mitigation process is not performance driven.

Noise (airport ground-based noise and vibration)

Type and magnitude of impact, pre and post mitigation has not been included

A single rating background level has been assumed for all receptors, this generalisation has

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Environmental issue Key issues raised underestimated the magnitude of noise impacts at receptors close to the airport.

Luddenham sensitive receptors were not included in background noise monitoring.

No cumulative noise impact assessment has been considered

The M12 motorway and the realignment of the Northern Rd has been excluded from the assessment regarding operational road traffic noise in Stage 1.

Local air quality and greenhouse gas (GHG) Local air quality assessment has several long term exceedances NO2, formaldehyde, PM2.5 and PM10

Effectiveness of proposed mitigation measures to achieve compliance was not quantified.

GHG emissions relatively small

Regional air quality Stage 1 assessment is acceptable

Ozone concentration significantly above allowable increment for longer term development

Community Health

Aviation planning No real visibility in draft EIS of how flight paths were determined

No presentation of alternatives

No certainty over final outcome

No consideration of point merge – impacts on Blaxland

Surface transport and access STM3 model has not been effectively calibrated and validated as the model is still in development with TfNSW

No traffic intersection modelling undertaken

Did not consider assessment of rail

Traffic estimate is based on 2011 which may be an underestimate as it does not include recent land use developments

Traffic generation (outside of air cargo) is unknown and no consideration made for passengers transferring within the airport.

Human health Reviewed air quality, noise and water impacts however no discussion on implications of the distribution of effects for inequality and equality have been discussed.

No rational or justification given on why a Health Risk Assessment (HRA) has been undertaken rather than a Health Impact Assessment (HIA)

Perceived health issues not considered

Social determinants of health have not been considered

Long term cumulative impacts were not considered.

Biodiversity and offset strategy Offset package has not been prepared and residual ecological risks have not been discussed

Mitigation measures are limited

Difficult to assess the biodiversity value of the site for the long term development.

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Environmental issue Key issues raised

Surface water and groundwater Duncan Creek and its tributaries have not been modelled to allow definition of baseline and hydraulic impacts

Draft EIS appears to dismiss any relevance of increased pollutant loads on the receiving environment

Groundwater assessment lacks qualification of data, no baseline time-series data collected

Two residual risks for groundwater were identified; soil and subsurface contamination from spill/release of chemical or contaminants and impact on groundwater dependant ecosystems from reduced water supply.

Social impact Balance of discussion on impacts – strong focus on economic benefits rather than a balanced discussion

Strong focus on regional benefits not local impacts

Many potential issues are stated with little assessment of their implications or level of significance or duration

No discussion on how mitigation measures will be co-ordinated or resourced or who the key accountability falls with

Claims being made by Commonwealth about economic generation and job creation have not been explicitly tested in the draft EIS

The draft EIS does not describe the economic or social impacts of any transfer of activity from other areas in Sydney or Australia.

Greater Blue Mountains A detailed assessment of significance under the Biodiversity Assessment for the Blue Mountains World Heritage Area has been deferred until a ‘multidisciplinary workshop’ is held to identify and assess potential impacts.

Limited assessment of wilderness value and high sensitivity

Noise levels predicted to be relatively low (below 50-55dB LAmax) however for a natural landscape is prediction is not justified and many impact the amenity values.

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1. Introduction WSP | Parsons Brinckerhoff were engaged by Western Sydney Regional Organisation of Councils (WSROC) and Macarthur Regional Organisation of Councils (MACROC and to project manage the Peer Review of the Western Sydney Airport draft Environmental Impact Statement (EIS) (Commonwealth of Australia, 2015a). A list of councils forming this engagement is provided in section 2.1.1.

This report provides:

an overview of the draft EIS

a summary of the peer review results against each of the key technical areas included in the draft EIS

an overview of the key issues of overall concern in relation to the draft EIS.

Detailed peer reviews of each of the assessed key technical areas have been appended to this report.

1.1 Background The proposed Western Sydney Airport project will be one of the largest and most complex infrastructure projects in Australia. The EIS prepared in 1997–1999 for the project by WSP | Parsons Brinckerhoff faced substantial community opposition associated primarily with aircraft noise, and the EIS was subject to intensive scrutiny. The Government at that time decided in 1999 not to pursue the project any further.

The political landscape has changed in the intervening years, and media coverage since the remobilisation of the project in 2014 suggests there is growing support mainly as a result of the project’s potential for local job creation. However, the project has some significant environmental and social impacts, with aircraft noise still being potentially the single biggest issue from the community’s perspective.

This review of the draft EIS has focused on a number of key issues, including aircraft and ground noise, airspace planning, air quality, social, traffic and transport and human health.

The Western Sydney Airport project is being assessed under the Environment Protection and Biodiversity Act 1999 (EPBC Act) as the proposal is being constructed solely on Commonwealth land (EPBC 2014/7391). The Commonwealth Department of Environment (DoE) issued guidelines for the content of a draft environmental impact statement for the Western Sydney Airport (EIS Guidelines) on the 22 of January 2015.

The draft EIS was released on public exhibition on Monday 19 October and will close on Friday 18 December 2015. Figure 1.1 illustrates the current status of the project in relation to the overall approval process.

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Figure 1.1 Program of assessment



2. Approach to peer review 2.1 Governance arrangements WSP | Parsons Brinckerhoff was engaged by WSROC and MACROC to undertake the peer review, and worked throughout the duration of the peer review process under the direction of a Steering Committee. A brief summary of the roles and arrangements for the governance of the peer review project is provided below.

2.1.1 Role of WSROC

The peer review has been managed by WSROC, acting on behalf of 11 councils from the WSROC and MACROC region. The participating councils, who have provided funding and guidance throughout the peer review, are as follows:

WSROC

Auburn City Council

Blacktown City Council

Blue Mountains City Council

Fairfield City Council

Holroyd City Council

Liverpool City Council

Parramatta City Council

Penrith City Council

MACROC:

Camden Council

Campbelltown City Council

Wollondilly Shire Council.

WSROC’s primary role is the overall management of the peer review on behalf of the councils, including managing the financial contributions from the participating councils, and the engagement and management of the peer review consultant (WSP | Parsons Brinckerhoff).

A dedicated WSROC project manager was engaged to undertake the following functions in relation to the project:

To manage the procurement process leading to the engagement of WSP | Parsons Brinckerhoff as the EIS Peer Review project managers.

To manage the financial contributions of the participating authorities in order to fund the consultant’s fees associated with the peer review.

To manage all ongoing contractual matters between WSP | Parsons Brinckerhoff and WSROC (including invoicing, scope management and project program).



To manage and facilitate the Steering Committee established for the EIS peer review (refer section 2.1.2 below) including convening Steering Committee meetings, and communication with the Steering Committee on relevant issues.

2.1.2 Role of the Steering Committee

The project has been managed under the direction of a Steering Committee comprising officer representation from each of the participating councils within WSROC/MACROC. The functions of the Steering Committee have been to:

Review and endorse the proposed scopes for technical specialists as part of a tendering process run by Parsons Brinckerhoff for the engagement of technical specialists.

Review and endorse the recommendations of WSP | Parsons Brinckerhoff in the selection of technical specialists (following receipt of submissions).

Discuss and agree any scope changes to the peer review following the appointment of WSP | Parsons Brinckerhoff

Review and provide feedback on the draft peer review report.

The Steering Committee met regularly during the peer review process.

2.2 Methodology The methodology adopted for this peer review of the draft EIS has been determined through a collaborative process between WSROC/MACROC and WSP | Parsons Brinckerhoff, under the general direction of the Steering Committee.

2.2.1 Project inception and early tasks

At the inception of the peer review, WSP | Parsons Brinckerhoff undertook a review the EPBC Referral, EIS Guidelines and previous EIS to identify topics for peer review (incorporating those topics identified by the brief).

These findings were presented to the WSROC Steering Committee in July 2015, which outlined the proposed program, proposed approach to scoping of peer reviews, proposed studies to be undertaken and appreciation of issues.

2.2.2 Preparation of the consultant briefs and nomination of potential specialists

WSP | Parsons Brinckerhoff prepared consultant briefs for a number of technical issues which were reviewed by the by the Steering Committee. These documents were written to ensure that submitted tenders were comparable with each other and are consistent in terms of general approach, terminology and language within the provided documentation.

Evaluation criteria were developed to allow a robust and transparent evaluation to occur.

In parallel with this, three suitable consultants for each topic were identified where possible by WSP | Parsons Brinckerhoff to bid for the review role. Consultants were identified based on their track record of similar projects with a particular focus on local experience where possible), their ability to deliver to challenging timeframes and their experience in peer review roles.



2.2.3 Evaluation and engagement of specialist proposals

Following Steering Committee endorsement of proposed scopes and shortlisted consultants, briefs were finalised and issued. The draft recommendations report was issued to the Steering Committee in August 2015 for review and the specialists listed in Table 2.1 were engaged to undertake their review:

2.2.4 Scope of the specialist peer reviews

The peer reviews were desk-based with no fieldwork, and no direct communication between the study authors and peer reviewers to ensure independence. The peer reviews for each technical issue evaluated whether the:

study meet the requirements of the EIS Guidelines and relevant other guidelines and methodologies;

conclusions reached in the studies are valid in accordance with published standards and guidelines, and whether the conclusions of the assessment are a realistic reflection of the actual impacts;

underlying assumptions are plausible;

mitigation and management measures proposed are adequate or have limitations in mitigating the impact;

level of uncertainty over impacts and the environmental risks; and

approach to the assessment of the long term development was appropriate.

The peer reviews provided a ‘plain English’ summary of the key impacts and opportunities associated with the project in relation to each specialist topic, so that the key findings could be readily understood by a broad audience.

Each of the draft peer reviews were reviewed by WSP | Parsons Brinckerhoff, before issuing these to the Steering Committee for review and discussion. Following the Steering Committee meeting to review the peer reviews, the draft peer reviews were finalised by the specialists.

2.2.5 Preparation of overarching review report

The focus of this review is on key environmental issues supported by specialist peer review reports which are included in Volume 4 of the draft EIS. To supplement and draw together the findings of the specialist peer reviews, his overarching review report has been prepared to:

Review the broader draft EIS including undertaking a gap analysis to identify aspects of the EIS that were not addressed by the specialist peer reviews – generally this includes the early chapters of the EIS that describe matters such as the project background, need and objectives, options considered, stakeholder consultation and project description and management frameworks.

To prepare an overarching review report that draws together the findings of the individual specialist reviews (including a summary of the most significant issues identified), incorporates the findings of the review of other aspects of the EIS (as described above) and provides an overview commentary on the results of the process.



2.3 Draft EIS review team Table 2.1 below identifies the peer review team chosen to review the draft EIS for the Western Sydney Airport.

Table 2.1 EIS review team

Environmental issue Peer reviewer Primary EIS Section for Review

Noise (aircraft overflight) Marshall Day Volume 4 – E1

Noise (airport ground-based noise and vibration)

WSP | Parsons Brinckerhoff Volume 4 – E2

Local air quality and greenhouse gas Katestone Volume 4 – F1

Regional air quality Katestone Volume 4 – F2

Community Health CHETRE Volume 4 - G

Aviation planning Arup, supported by The Airport Planning Group

Volume 4 – H Volume 4 – I

Surface transport and access Arup Volume 4 – J

Biodiversity EMM Volume 4 – K1

Offset strategy EMM Volume 4 – K2

Surface water hydrology and geomorphology

Cardno Volume 4 – L1

Surface water quality Cardno Volume 4 – L2

Groundwater Cardno Volume 4 – L3

Social impact Hill PDA Volume 4 – P1

Property values Hill PDA Volume 4 – P2

Greater Blue Mountains WSP | Parsons Brinckerhoff Volume 2, Chapter 26

The qualifications of each reviewer is provided in the relevant peer review provided in Appendix A–I of this report.

2.4 Limitations Due to the limited exhibition period of the draft EIS (which required specialists to prepare their draft peer review reports within three weeks of the start of exhibition), and the agreed approach to the peer review (Chapter 2 – Approach to peer review) several limitations were identified in undertaking the review including:

The peer review included a desktop assessment only. No site inspections were undertaken as part of the review by WSP | Parsons Brinckerhoff or the peer reviewers.

No consultation has been undertaken between the peer reviewers and the project team involved in preparing the draft EIS.

The results of several of the specialist reports (noise, air quality, transport) relied on results generated from a project specific model. These models where not made publically available, despite a direct request from WSROC to the Department of Infrastructure and Regional Development, and therefore a detailed review was not possible.

No additional modelling was undertaken to verify the results of any of the technical reports.



A detailed review of the draft airport plan was not undertaken, however, it was referred to ensure consistency with the draft EIS.

2.4.1 Technical reports excluded from review

Not all of the technical reports presented in the draft EIS were reviewed. This was generally because certain issues, while locally important, were not considered to be key issues for the broader region covered by the WSROC and MACROC LGAs, and so did not represent value for money for the project. It was also understood that individual member authorities could choose to undertake additional review work outside the scope of this project. As a result the following technical reports have been excluded from this peer review:

Aboriginal cultural heritage

European and other heritage

Landscape character and visual

Other ‘non-key’ issues such as contamination, resources and waste and topography, geology and soils (Separate review on waste will be prepared by WSROC and MACROC).



3. Review of the overall draft EIS

WSP | Parsons Brinckerhoff undertook at preliminary review of the broader EIS and its compliance with the Guidelines for the content of a draft environmental impact assessment, Western Sydney Airport. Table 3.1 below provides a summary of the compliance of the draft EIS.

Table 3.1 Summary of compliance with EIS guidelines

Comments

General content Volume 1, Section 8 described an EIS summary report which was to have been prepared to assist the general public to understand the key issues of the draft EIS without having to read.

The draft EIS seeks approval only for the construction and operation of the Western Sydney Airport until 2030. The draft EIS doesn’t fully consider all the impacts on the environment during this period as it uses indicative flight paths. The long term environmental impacts (beyond 2030) are also unclear.

Format and style The draft EIS is generally compliant with the format and style required.

It would be useful to have an overall table of contents at the start of each volume. The draft EIS only has a table of contents for each Volume which makes it difficult to find specific information across the four volumes.

General information This section is generally compliant however, more discussion could be made around how the action relates to other actions in the region, including significant state road and rail projects and urban development projects and their associated impacts.

Description of the action This section is generally compliant. The inclusion and description of development beyond 2030 is at times confusing for the reader as not all impacts are known and it does not form part of the works to be assessed under Stage 1 of the draft EIS or the draft airport plan.

Feasible alternatives More details could be provided about the feasible alternatives, especially in relation to airspace planning and the short, medium and long term advantages and disadvantages of the options.

Description of the environment The description of the environment is generally compliant however, it is noted that not all sensitive receivers have been considered.

Relevant impacts A key concern of the draft EIS is the description of impacts and residual impacts. As the airspace planning is based on indicative flight paths a detailed assessment of the nature and extent of likely short-term and long-term relevant impacts is not able to be undertaken with any certainty.

It is recommended that prior to the determination of the EIS and airport plan more certainty is provided around airspace planning so a more robust assessment of impacts such as noise, air quality and health can be undertaken.

Avoidance and mitigation measures A consolidated list of mitigation measures has been provided in section 28.4 of the draft EIS however a detailed description of the expected or predicted effectiveness has not been included. Refer to section 3.3 of this report for more detail.

Residual impacts and offsets The residual impacts and offsets are not clearly defined or summarised in the draft EIS and are scattered throughout Volume 2. This does not give the community any certainty as to the predicted short and long term impacts.



Comments As described in section 4.9 and Appendix I of this report, a Biodiversity Offset package has not been formalised.

Environmental record of person(s) proposing to take the action

The draft EIS has adequately addressed this component.

Other approvals and conditions The draft EIS has adequately addressed this component.

Economic and social matters Refer to Section 4.6 below

Information sources provided in the EIS

The draft EIS has adequately addressed this component.

Conclusion This section of the draft EIS generally complies however given the uncertainty surrounding the airspace planning and indicative flight paths a more precautionary approach is recommended in section 29.5 – Consideration of the principles of ecologically sustainable development.

3.1 Planning and land use statutory approvals context The Western Sydney Airport will be subject to Commonwealth environment and development approvals framework as the project occurs solely within Commonwealth land.

Development at existing federally leased airports require approval under the Airports Act 1996 (Airports Act). As the Western Sydney Airport site is a greenfields site and there is no current airport lease, the Airports Act was amended in June 2015 to allow planning, environment and development approval for the Stage 1 development of the proposed airport. The Airports Amendment Act (July 2015) allowed for the preparation of an Airport Plan as a transitional planning instrument to describe the initial development of the site and be supported by an EIS to assess the first stage of the airport development. Prior to the determination of the final Airport Plan the Minister for the Environment is required to give notice stating if the draft Airport Plan should be determined or not and under what conditions , considering the outcomes of the final EIS.

A draft EIS has now been prepared to support the draft Airport Plan which is also currently on exhibition as part of the overall EIS package of documents (http://westernsydneyairport.gov.au/airport_plan/index.aspx). Following the exhibition period both these documents will be finalised and considered by the Minister for Environment and the Minister for Infrastructure and Regional Development for determination (refer to Figure 3.1).

http://westernsydneyairport.gov.au/airport_plan/index.aspx



Source: Commonwealth of Australia 2015a

Figure 3.1 Approval process

As the proposed Western Sydney Airport is to be located solely on Commonwealth land, the Airports Act and the EPBC Act authorises development and excludes the operation of any New South Wales (NSW) state law. A range of NSW and local government planning documents have been considered in the preparation of the draft EIS and draft Airport Plan.

3.1.1 Draft Airport Plan

The draft Airport Plan primarily describes the proposed Stage 1 works for the construction and initial operations of a single 3,700 metre runway located in the north-western portion of the site and a range of aviation support facilities including passenger terminals, cargo and maintenance areas, car parks and navigational aids is the subject of this draft EIS. Part 3 of the draft Airport Plan describes the construction works and operational needs to cater for the predicted demand for the first five years of operation to around 2030 of approximately 10 million passengers per year as well as freight traffic. Site preparation activities are proposed to commence in mid-2016.

Development beyond Stage 1, will be undertaken under the existing planning framework in Part 5 of the Airports Act, including the preparation of a major development plan for any significant development at the airport. Significant future works, such as a second runway, which may have an impact on matters of National Environmental Significance may require a Referral under the EPBC Act. Table 3.2 provides a summary of the activity forecast for Stage 1 and beyond.

Section 3.2.3 of this report provides further detail on the approval process for the longer term development of the airport.



Table 3.2 Summary of activity forecasts

Stage 1 (c. 2030) First runway at capacity (c.2050) Long-term (c.2063)

Annual passengers (arrivals and departures)

10 Million Annual Passengers (MAP)

37 MAP 82 MAP

Busy hour passengers (international and domestic)

3,300 9,500, 18,700

Total annual aircraft traffic movements (ATM) (passenger and freight)

63,000 185,000 370,000

Total busy hour ATM 21 49 85

Source: Commonwealth of Australia (2015) Draft Airport Plan

3.2 General observations WSP | Parsons Brinckerhoff broad review of the draft EIS, in consultation with the WSROC and MADROC Steering Committee has identified several key areas of concern, the most significant being the lack of detail and certainty around airspace planning (or ‘airspace architecture’). Other key concerns relate to the decision to define Phase 1 (i.e. the scenario for which the EIS seeks approval) as the level of operational activity at 2030. This results in an assessment of a level of airport activity well below the theoretical maximum that the initial single runway development could accommodate (63,000 air movements annually, compared to an theoretical maximum of 185,000) Other concerns relate to the high level traffic assessment, adequacy of the health impact assessment and the uncertainty over the longer term development of the airport.

3.2.1 Airspace planning (Airspace architecture)

A key concern of the draft EIS relates to the approach to determining the flight paths (or airspace architecture) and the indicative nature of the flight paths. This section provides a brief overview of the key issues relating to airspace planning, a detailed review is provided in section 4.5 and Appendix C of this report.

Key technical reports which support the draft EIS including aircraft noise and air quality assess impacts of the project over a wide area have undertaken their assessment based on indicative flight paths. The draft EIS notes that it is expected that these flight paths would be ‘progressively refined during a detailed design process which would provide the opportunity to optimise safety, efficiency, noise and environmental impacts before operations begin at the proposed airport’. The draft EIS is not clear on the process for these reviews and assessments to occur except to say that they ‘may require further environmental assessment processes to assist decision making and may be the subject of a future referral under the EPBC Act following detailed design’. It is not clear if a future EPBC referral would be required for a change in flight paths, the Airports Act notes that this can be assessed under a major development plan (MDP) which would not need approval from the Minister for the Environment, only that the Minister for Infrastructure needs to obtain and consider advice from the Minister for the Environment.

The EIS additionally makes clear that the flight paths presented in the EIS were determined based solely on operational and aviation safety considerations, and that minimising noise impacts was not a consideration in establishing the flight paths presented (other than the fact that the proposed flight paths were then subject to noise impact assessment).

As the flight paths relate directly to the Stage 1 assessment, the uncertainty associated with the flight paths that might ultimately eventuate would ideally need to occur prior to determination of this current assessment



to ensure the environmental impacts and risks are properly assessed and the local community informed. We are well aware that in the absence of a future airport operator, the Commonwealth will be reluctant to give more certainty in relation to flight paths.

Specific issues associated with the uncertainties around flight paths, and which are considered further in section 4.5, include:

Location of the merge point at Blaxland is also indicative until the flight paths are finalised. Currently Blue Mountains City Council and Penrith City Council are very affected by aircraft noise associated with this merge point, however, this is also only indicative.

Lack of consideration of alternative flight paths including greater consideration of Kingsford Smith, Camden, Richmond and Bankstown airports. In particular it is thought that the impacts on Bankstown airport have not been fully addressed.

The draft EIS lacks sufficient detail in airspace architecture including a detailed description as what the underlying principles were, how was it developed and any alternatives which were considered.

The draft EIS did not look at any scenarios beyond the normal/scheduled operation of the airport such as queuing in the event of unscheduled interruption.

Further analysis of the proposed fleet mix is required. It is not considered suitable to adopt the fleet mix used from Kingsford Smith Airport (KSA) and that further analysis of the preferred fleet mix at the Western Sydney Airport should be undertaken.

A detailed discussion to determine whether a curfew is required. We recognise that this is a substantial political issue, we sought to investigate the level of night time impacts that might provide a clear basis for the need or otherwise for a curfew. Based on current information, there is not enough information to determine if a curfew is required (from the perspective of compliance with noise standards for sleep disturbance) or not.

3.2.2 Short term assessment within the draft Airport Plan

Whist the draft EIS and associated technical reports provide some detail and assessment on the longer term development of the Western Sydney Airport, the draft EIS is seeking approval only for the construction and operation of Stage 1 until approximately 2030.

The draft EIS notes that by 2050 the single runway will have reached capacity (refer to Figure 3.2 of this report) and a second runway will be required. A general recommendation is that the draft EIS should consider the operation of the airport at 2045 (approaching full capacity of the single runway infrastructure) so the community and stakeholders have a greater understanding of the impacts of a single runway airport.

3.2.3 High level traffic and transport assessment

The traffic and transport assessment assessed in the EIS for Stage 1 works provides a high level assessment of traffic directly relating to the construction and operation of the Stage 1 works until 2030. Whilst it appears that by using the data discussed, the assessment undertaken is largely correct however it is considered that all the impacts are not able to be validated as the following information is not provided or considered:

freight traffic generation within the Airport precinct (outside of air cargo)

private vehicle traffic generation from land uses within the Airport precinct (outside of air passengers)

vehicle travel time comparison (as predicted by strategic modelling)

intersection performance (as predicted by intersection modelling)

intersection layout requirements (as predicted by intersection modelling).



It is noted that the proposed Western Sydney Airport is supported by the Western Sydney Infrastructure Plan (WSIP) which is a 10 year project investing in major road infrastructure upgrades in Western Sydney. As the Western Sydney Airport is not going through the NSW state approvals there are no mechanisms to ensure the upgrades proposed in the WSIP occur, or occur in the timeframe required for the Western Sydney Airport project. Also, as described about and in section 4.3 of this report, the draft EIS did not undertake any assessments of intersections to determine if the proposed upgrades are adequate (refer to section 4.3 for more detail).

3.2.4 Uncertainty over longer term development and cumulative impact

The draft EIS provides a discussion on the long term development of the airport. This discussion generally focuses on the development of a second runway and the associated impacts, however at this stage all the impacts are indicative and will not form part of the Stage 1 approval process.

The long term development discussion presented in the draft EIS does not provide a comprehensive evaluation of impacts. We consider that it is reasonable not to attempt a full and detailed assessment of the airport at 2023, as there will be too many variables that are not known at that stage (such as aircraft types, the conditions of the receiving environment, and the pattern of urban development in Western Sydney).

However, we consider that the EIS could have been bolder in its assumptions about the long term development of Sydney. The EIS is largely limited to identifying known development plans, such as the urban development associated with the growth centres and Western Sydney Employment Area. More discussion on the long term strategic planning initiatives within the region and the impact these future land uses may have on the airport would be beneficial.

3.2.5 Lack of State integration

The proposed Western Sydney Airport occurs solely within Commonwealth land and therefore does require approval from the New South Wales (NSW) government (i.e. it is exempt from state planning laws). Despite this, there are several significant infrastructure projects such as the WSIP and South West Rail Link Extension which the Western Sydney Airport rely on to be able to operate effectively and reduce the impact on the local community and stakeholders. In addition to these infrastructure projects, the long term strategic planning and future land uses of the greater South Western Sydney region needs to be considered.

Ordinarily, for a major project being assessed under the NSW planning approvals regime, the various other state agencies, including the infrastructure delivery agencies (such as Councils, Roads and Maritime Services and Transport for NSW) would be an integral part of the assessment process (generally led by the NSW Department of Planning and Environment and Minister for Planning). In this capacity they would be actively involved in the development of planning conditions governing a range of matters including, for example, the management of road capacity for major traffic generating developments. Planning contribution mechanisms (requiring financial contributions to upgrade infrastructure associated with the project) would also be established through state legislation.

We are aware that Federal funding has been agreed for a substantial package of road upgrades in the vicinity of the project (the Western Sydney Infrastructure Plan - WSIP). However, as discussed above and in more detail in Chapter 4 of this report, there is no mechanism discussed to ensure that these projects are approved and completed in a timeframe complimentary to the development of the Western Sydney Airport. There is also no certainty around the mechanisms for infrastructure funding beyond the provisions of the WSIP.



3.3 Management and mitigation measures Once an airport lease has been granted, the Airports Act and the Airports (Environment Protection Regulations 1997) determine the management of activities at airports that have the potential to cause environmental harm. As no airport lease has been granted, the management and mitigation measures for Stage 1 of the proposed Western Sydney Airport have been described in the draft EIS and it is assumed that they would be implemented as proposed.

The draft EIS provides a range of management and mitigation measures for Stage 1 of the Western Sydney Airport for each of the key impacts. A general concern amongst all specialist reviews was that the mitigation measures are generic in nature, primarily due to the uncertainty of the impacts assessed. The effectiveness of achieving compliance through the mitigation measures is also generally not quantified. The type and magnitude pre and post mitigation is often not described.

No specific social management and mitigation measures have been adopted, rather referencing any measures referred to in the technical reports were relevant. A key management and mitigation approach for aircraft noise includes insulation of existing dwellings however there are no details on what this would entail.

Generally, the management and mitigation measures beyond 2030 are not known. The management of the airport beyond 2030 will be described in the Environment Strategy prepared by the lessee in accordance with the Airports Act and the Airports Regulations. The Environment Strategy is not likely to require the same level of scrutiny or approval by Minister for the Environment as does the works described under Stage 1 of the draft EIS. It is again recommended that the works proposed under Stage 1 EIS is extended to include works to allow the full capacity of the single runway so management and mitigation measures can be developed more long term and greater certainty given to the community and key stakeholders.

3.4 Consultation activities DoE’s guidelines for the draft EIS do not specially state any requirements for consultation except that the proponent is required to make the draft EIS available for public exhibition. Community and stakeholder engagement undertaken during the preparation of the draft EIS is discussed in Part C, Volume 1 of the draft EIS and generally appears to be adequate for the level of consultation expected for a major project.

The following items have been raised in regards to the consultation section:

The Community and Engagement Strategy for the Project addressed the needs of the target audience based on initial community research and stakeholder consultation which included 11 focus groups and an online survey. The online survey was undertaken for residents within a 20 kilometre radius around Badgerys Creek, which excludes most of the Lower Blue Mountains which may be impacted by aircraft noise and amenity of low flying planes. There is also some confusion in the number of residents which were surveyed, Section 8.2.2 – Community and Engagement Strategy refers to 2,041 however Table 8-1 in Section 8.3 – Phase 1 – draft EIS and draft Airport Plan preparation mention 3,041.

Table 8-7 of Section 8.4.1 – Stakeholder and community engagement programme refers to a plain English EIS summary being developed for the stakeholders and community which would be available at community events, online and at static display locations. The Western Sydney Airport website does not contain this summary paper so it is unclear whether it has been prepared.

Section 8.5 – assessment and determination refers to an online mapping tool which is not discussed anywhere else in the document. Further discussion on what this tool does would be beneficial.



4. Review of technical reports 4.1 Noise

4.1.1 Aircraft overflight noise

4.1.1.1 Approach

The peer review has been primarily based on information presented in the noise chapters for the Stage 1 proposal and long term developments, in conjunction with the technical noise report presented in Appendix E1 of the draft EIS.

Consideration has also been given to other related sections of the draft EIS to review the broader assessment of noise impacts. The review of these additional sections has been concerned solely with matters related to the aircraft noise assessment. Reference should be made to the separate peer reviews commissioned by WSP Parsons Brinckerhoff for the review of specialist matters directly concerning aviation, fauna, health, planning and social issues.

This peer review addresses the following key elements of the aircraft noise assessment:

The noise prediction methodology and the associated inputs and assumptions;

The type of noise level information that has been produced;

The operational scenarios that have been considered in the noise predictions;

The noise sensitive receptors that have been identified and considered in the assessment;

The methods used to assess the impact of the predicted noise levels;

The proposed noise mitigation and management measures; and

The level of uncertainty concerning the predicted noise impacts and environmental risks.

In reviewing these aspects of the draft EIS, consideration has been given to the document Guidelines for the content of a draft Environmental Impact Statement – Western Sydney Airport (Reference: EPBC 2014/7391 and subsequently referred to as the EIS guidelines).

4.1.1.2 Review findings – Stage 1 Development

The noise modelling is considered to generally provide a reasonable representation of the extent of noise impacts for the specific flight tracks and operating scenarios that have been proposed. Specifically, predicted noise levels have been determined for a range of operating scenarios. Aircraft noise information has also been produced in a range of formats that are generally consistent with current federal government guidelines for identifying areas potentially affected by aircraft noise.

All noise predictions have been determined using the latest version of the US Federal Aviation Authority’s Integrated Noise Model (INM). This software is used widely in Australia and internationally for aircraft noise predictions and is the appropriate choice for this application. However, the use of this software to calculate short noise levels, which is the main form of noise data used in the draft EIS to identify the extent of affected areas, requires careful consideration. Specifically, the INM supporting documentation notes:



INM is not designed for single-event noise prediction, but rather for estimating long-term average noise levels using average input data. Comparisons between measured data and INM calculations must be considered in this context.

Accordingly, while the use of the INM is reasonable, information has not been provided as part the draft EIS to verify the reliability of the short term noise level data (presented as maximum noise levels and Number Above ratings). This is particularly important for this proposed airport, because of the increased uncertainty associated with the predictions at the lower noise thresholds used in the draft EIS for the assessment of night-time operations and impacts in quiet areas such as the Greater Blue Mountains World Heritage Area.

Notwithstanding the general suitability of the noise modelling data, there are however a number of limitations to the assessment. These relate to the uncertainty surrounding the airspace management design, and the limited assessment of the noise modelling outcomes. These matters are summarised as follows:

Low Stage 1 movement numbers

The total aircraft movement numbers for the Stage 1 development are relatively low when compared to other international airports in Australia. The low movement numbers cast doubt over the suitability of the 5 year time horizon as the primary assessment scenario for the purpose of obtaining approval for a major international airport. In this context, it is unclear how the incremental and periodic approvals that would need to occur as part of the ongoing expansion of the airport provide a sufficient basis for considering the initial 5 years of operation as the primary period for the assessment of noise impacts.

These comments are provided primarily in relation to the plausibility of the movement numbers represented in the noise modelling, based on comparisons with movement numbers documented in the noise modelling for other Australian international airports and similar time horizons. Aircraft traffic forecasts are however outside of our area of expertise and therefore the suitability of the specific movement numbers provided for the noise assessment are considered in further detail in separate aviation peer review commissioned by WSP | Parsons Brinckerhoff.

Airspace management strategy uncertainties

The draft EIS states that the airspace management strategy used as the basis for noise modelling is a proof-of concept design, and that further work is required to determine the actual flight paths which would be flown in practice. Information about the extent of potential change in flight paths is limited. The uncertainty surrounding the final airspace management design that would be implemented represents a significant source of uncertainty in the noise assessment. The potential significance of this source of uncertainty has not been quantified and, with exception of alternative merge points for Stage 1, there has not been any sensitivity analysis carried out to assess the implications of potential flight path changes.

Assessment of community annoyance

The draft EIS includes exposed population statistics which provide a useful indication of the potential scale of the community who may be affected by aircraft noise to varying degrees. However, in isolation, this data does not provide an indication of the scale or significance of potential community reaction to aircraft noise levels as a result of annoyance. The Health Risk Assessment in the draft EIS provides the most discussion of community annoyance, including references to research concerning the relationship between noise exposure and community annoyance. However, the Health Risk Assessment ultimately states that no quantitative assessment of annoyance was conducted as part of the study.

Dose-response relationships of the types referenced in the Health Risk Assessment can be used with noise levels and population data to provide a quantitative measure of the potential reaction. The use of these established relationships to represent the reaction of a separate community exposed to aircraft noise must be used with caution. In particular, due consideration must be given to the increased reaction that may be expected from a newly exposed community. However, this type of analysis provides an objective basis for



comparing the impacts of alternative operating strategies and, more broadly, establishing the risk of community noise impacts relative to other established international airports in Australia.

While the assessment of the risk of community annoyance is complex, the scale of the proposed airport and the number of people potentially affected warrant further evaluation of the subject. The introduction of a new 24-hour international airport at a greenfield development site introduces a risk of widespread and prolonged community annoyance. A quantitative analysis of this potential risk would be prudent to inform the environmental impact assessment process and the extent to which operational noise mitigation should be prioritised relative to other non-safety related airspace management considerations. Updated social surveys of the type originally carried out as part of the development of the Australian Noise Exposure metric used in Australia also warrant some consideration, given the significant nature of the proposed development and the availability of detailed aircraft noise information for other existing Australian airports.

Land use impacts

The draft EIS includes calculated Australian Noise Exposure Concept (ANEC) contours for the Stage 1 operating scenarios. ANECs are often presented as an indication of the extent of a potential future Australian Noise Exposure Forecast (ANEF) contour which would be used to guide land use planning for noise-sensitive developments in the vicinity of airports.

However, the ANEC contours presented for the Stage 1 proposal provide limited guidance for the purpose of land use planning. The reason for this is that the ANEF is normally derived from ANECs calculated for long term operations or ultimate capacity scenarios, rather than short term ANECs related to an initial phase of operation. Evaluation of land use planning impacts must therefore be primarily based on the ANEC contours presented for the long term development of the airport, rather than initial Stage 1 development contours.

Greater Blue Mountains World Heritage Area

The draft EIS presents information to evaluate the potential impacts of aircraft operations on the acoustic amenity of the Greater Blue Mountains World Heritage Area (GBMWHA). The assessment indicates the potential for a large number of audible aircraft events within the GBMWHA.

The preservation of quiet areas and tranquil landscapes has been a topical subject of research and policy consideration in Europe and the US. For example, US publication (Transportation Research Board, Airport Cooperative Research Program, Mestre 2008) on the effects of aircraft noise includes a chapter which discusses research and US legislation (National Parks Over ight Act of 1987) concerning the effects of aviation noise on parks, open space and wilderness areas. These publications do not provide definitive guidance on assessment techniques, but highlight the complexity and importance of assessing aircraft overflight noise in sensitive wilderness areas.

While the noise levels in the draft EIS are predicted to be relatively low (below 50–55 dB LAmax), aircraft over flights would be expected to be audible and represent a significant and widespread impact for a World Heritage Area where natural soundscapes are likely to be a valued feature of the areas amenity. The complexities and sensitivities of this area warrant further consideration in the draft EIS. Specifically, the assertion within the draft EIS chapter concerning the GBMWHA that noise levels below 50 and 55 dB LAmax are ‘not significant’ is not considered to have been sufficiently justified, and the assessment may therefore not adequately reflect the potential impact to the values of tranquillity within the World Heritage Area.

Mitigation measures and residual noise impacts

The draft EIS noise modelling is based on an indicative proof-of concept air traffic management design which does not present a comprehensive airspace and final air route design. Given the uncertainties concerning the final form of the airspace design, the final form of noise mitigation measures to be implemented is not yet known. Accordingly, the mitigation measures that have been referred to in the aircraft noise assessment are generic in nature.



This is a particularly important point for an airport development as, unlike other forms of infrastructure development, the policies used to manage aircraft overflight noise do not generally stipulate noise limits that airport operations must adhere to at surrounding noise-sensitive locations.

Accordingly, without a defined airspace design, a defined noise mitigation strategy or defined noise criteria to adhere to in practice, the residual impacts and the location of these impacts is subject to considerable uncertainty. Further, without defined noise criteria, it is unclear how noise considerations would be prioritised among other non-safety related airspace management and operational considerations associated with the proposed airport site. These uncertainties may therefore warrant consideration of performance criteria as part of the approval process for the proposed airport.

In addition to the generic operational measures for the mitigation of noise, the draft EIS also refers to mitigation related to dwelling acquisition or dwelling insulation upgrades. There is however no detail provided in terms of the circumstances in which these measures would be implemented, other than a general reference to the guidance of AS 2021. It is unclear if this is intended to infer that such measures would only be considered within certain Australian Noise Exposure areas, or if such measures would be considered at all locations where internal levels may be expected to exceed AS 2021 internal design criteria as a result of the proposed aircraft operations.

4.1.1.3 Review Findings – Long Term Development

A number of the considerations identified from the peer review of the Stage 1 development are directly relevant to the assessment of the long term development scenarios. For example, matters related to the noise prediction methodology are identical for the Stage 1 and long term development scenarios.

In terms of assumptions about operational capacity, the movement numbers for the 2050 single runway scenario and 2063 dual runway scenario are comparable to the range of movement numbers documented for other similar Australian international airports. On this basis, the values appear to be plausible for noise assessment purposes. Aircraft traffic forecasts are however outside of our area of expertise and therefore the suitability of the specific movement numbers provided for the noise assessment are considered in further detail in separate aviation peer review commissioned by WSP | Parsons Brinckerhoff.

The following limitations are however noted for the long term assessment scenarios.

Land Use Impacts

The draft EIS presents ANECs for a range of operating scenarios in 2050 and 2063 as part of a discussion of the potential land use impacts which may result from a future ANEF for the proposed airport.

However, the latest Australian Standard (AS 2021) which defines how Australian Noise Exposure data should be used to inform land use planning, includes guidance on how ANECs for multiple operating scenarios may be combined to define an overall area where planning controls should apply. The draft EIS does not refer to this guidance and it is therefore unclear how the various ANECs should be interpreted when assessing land use impacts.

Further, while the draft EIS provides population counts for the various ANEC bands, no assessment is provided of the extent to which land use controls may change as a result of a future ANEF prepared as part of the detailed airspace design for the project. Specifically, the draft EIS does not quantify the potential extent of changes to land use controls relative to the measures which have been in place since the original EIS was undertaken in 1985. Furthermore, the discussion of land use planning impacts in the draft EIS notes that the National Airports Safeguarding Framework would ‘be instrumental in managing potential future operational noise impacts for future land use planning and development around the airport’. The Framework could potentially translate to the creation of land use planning controls which extend over significantly greater areas than either the current land use planning controls (based on the 1985 EIS) or the 2063 ANEC contours provided in the draft EIS. This has however not been discussed or assessed in the draft EIS.



Cumulative Impacts

The draft EIS notes that the parallel runway scenario (2063) would introduce a number of issues which would need to be addressed in the final airspace design. In particular, the chapter concerning airspace architecture notes the following issues that would need to be addressed:

Changes to Sydney Airport flight paths;

Changes to flight paths serving Bankstown Airport; and

Resolution of a potential constraint associated with the restricted airspace over Defence Establishment Orchard Hills.

The EIS guidelines establish a requirement to ‘identify and address cumulative impacts, where potential project impacts are in addition to existing impacts of other activities’.

The above issues concerning the airspace architecture are considered to represent potential cumulative impacts which have not been quantified in the draft EIS. Further information concerning this issue is therefore considered necessary to address the requirements of the EIS guidelines.

4.1.1.4 Key Impacts and Opportunities

The findings of the peer review indicate that noise level information of the form required by the EIS guidelines has generally been provided in the draft EIS. However, the peer review has also identified a number of limitations concerning the content of the draft EIS, and therefore further information and assessments are considered necessary to address the general and noise-specific requirements of the EIS guidelines.

Based on the review of the draft EIS, the key noise impacts associated with the proposed airport are:

Community annoyance, and related impacts such as speech interference and changes to the way individuals use outdoor spaces.

Sleep disturbance associated with night-time operations, and related impacts such as the potential need for some residents to sleep with windows closed to achieve a suitable internal amenity.

Degradation of the acoustic amenity of the World Heritage Area within the Greater Blue Mountains area.

In terms of land use impacts, the existing planning instruments that have been used to control development around the proposed airport site would generally be expected to limit the extent of the potential impacts. However, the draft EIS reference to the National Airports Safeguarding Framework as an instrumental tool for guiding future land planning around the proposed airport site introduces the potential for significantly enlarged development controls. This could translate to land use impacts also being a key impact associated with the proposed development.

Other noise related impacts cornering matters such as health, property values and social impacts are addressed in separate peer reviews commissioned by WSP | Parsons Brinckerhoff.

Aircraft noise impacts are ultimately an unavoidable consequence of aircraft operations in urban environments. The creation of a new international airport therefore requires a balance to be achieved between the protection of amenity for neighbouring sensitive land uses and the development of infrastructure to respond to the growing demands of a major city.



Determining whether this balance has been achieved is ultimately a matter for regulatory authorities. While this peer review has identified a number of limitations to the present assessment, this is not intended to infer that the proposed development and development site are unsuitable. Rather, in light of the residual uncertainties in the assessment, further information and assessments are considered necessary before stakeholders can reach an informed view on the potential scale and significance of aircraft overflight noise impacts associated with the proposed airport site.

Conducting these further assessments as part of the environmental impact assessment process represents an opportunity to:

provide clarity to affected communities and stakeholders about the nature of the noise impacts;

provide clarity to regulators about the form of noise controls which will be needed in the project approval to ensure that noise is appropriately managed; and

reduce the potential for unforeseen impacts and the associated risk of reactionary noise management procedures which could subsequently jeopardise the operational flexibility of the proposed airport.

4.1.2 Ground based noise and vibration

4.1.2.1 Approach

This review identified uncertainties and unknowns within the ground noise assessment, provided in the EIS and identified what further assessment would be required to provide an indication of impacts. The limitations of this review are as follows:

Noise modelling or review of noise modelling files has not been completed as part of this review. Therefore, it was not possible to verify the noise contour plots from ground-based activities presented in the draft EIS. However, comment has been included based on a visual inspection of the plots.

The review relies on the source noise data that has been included in the ground noise assessment. The review is a desktop exercise and therefore, independent source noise measurements have not been conducted to confirm the noise levels used for taxiing and engine ground running as presented in the EIS.

The components of the review are follows:

The review comments on the draft EIS chapters relevant to ground noise in addition to Appendix E2 – Airport ground-based noise and vibration. This appendix is the technical basis for all other ground noise related documents, including the relevant draft EIS chapters.

A document review is contained within Appendix A of Appendix B this report, and provides references and comment on specific sections of the draft EIS.

4.1.2.2 1st stage airport

A summary of the findings for the 1st stage airport is as follows:

The assessment does not fulfil the requirements of the Guidelines for the Content of a Draft Environmental Impact Statement – Western Sydney Airport 2015 (EIS Guidelines). These guidelines state that the type and magnitude of impact, both pre-mitigation and post-mitigation should be presented. The ground noise assessment should be updated to include this assessment.

There is insufficient detail to satisfy the EIS Guidelines on the source of the noise data and assumptions used in noise predictions. As these assumptions form the basis for the noise assessment, changes to the source noise data could potentially lead to a significantly different outcome.



The assessment does not provide sufficient justification to support the assessment being performed based on the year 2030 (5 years after opening) and not 2050 when the airport is expected to be approaching capacity for the single runway configuration with potentially increased noise impacts.

The report does not provide sufficient detail in the assessment of the ground-based power supply to aircraft when they are parked. The assessment excludes the use of Auxiliary Power Units (APU), however it does not provide sufficient detail of alternative ground-based power supplies. As an alternative power supply method is not presented, there is potential for additional noise sources being introduced that have not been considered.

Background noise monitoring was conducted at 10 locations in the region, however a single background level has been assumed for all receptors, rather than several location-specific values. This generalisation has underestimated the assessment noise criteria and therefore the magnitude of noise impacts at receptors close to the airport that are currently exposed to low levels of environmental noise.

The nearest noise sensitive receptors in Luddenham were not included in the background noise monitoring and therefore, there is uncertainty if noise impacts have been adequately assessed at this location.

No consideration has been given to the cumulative noise impact from all ground noise sources at the nearest noise sensitive receptors both with and without mitigation measures as required by the EIS Guidelines. Additional assessment should also be undertaken for other ground noise sources, such as the compass calibration pad.

It is recommended that the mitigation measures identified in the assessment, including the restriction of APUs and the limitation of engine ground run-ups during the night, are formalised as part of the project approval.

The assessment does not provide sufficient evidence that all reasonable and feasible mitigation measures have been considered to reduce noise impacts from taxiing and ground run-ups.

Semi-enclosed pens and bunded areas to reduce noise impacts from engine ground run-up noise are considered in the assessment. It is recommended that these measures are considered further as part of the approvals and subsequent design stages.

No comment has been made on the potential cumulative noise impact from the new M12 Motorway and realignment of The Northern Road that are being developed to accommodate the airport.

The EIS contains misleading statements relating to operational road traffic noise which do not acknowledge the limitations of the assessment. The development of the M12 Motorway and realignment of The Northern Road have been excluded from the assessment and statements regarding operational road traffic noise should include these limitations.

4.1.2.3 Long term development review findings

The assessment is considered to contain an appropriate level of detail for the long term development as the potential noise impacts are predicted for a considerable time in the future (into 2063). It is acknowledged that the noise environment may change over time.

The comments raised in this review for the 1st stage airport assessment should be addressed and applied to the long term development assessment. Where this occurs, the current framework for further assessment of the long term development is considered appropriate.

The EIS does not include ground-based noise in the summary or conclusion for the long term development. It is recommended that the outcomes of the revised long-term development ground-based noise assessment are included in these sections so that all impacts are clearly presented.



4.1.2.4 Key impacts and opportunities

It is considered that the ground-based noise assessment does not provide an appropriate level of detail on a number of key aspects including:

the derivation and allocation of assessment criteria

noise impacts at the nearest sensitive receptors in Luddenham

noise source levels and modelling assumptions

the type and magnitude of impacts with and without mitigation

evidence that all reasonable and feasible mitigation has been considered

cumulative noise impacts from operational activities and road traffic projects.

As a result, without further clarification or justification, it is uncertain that the draft EIS has adequately presented and addressed the noise impacts associated with the proposed development.

It is recommended that these items are addressed to reduce the level of uncertainty, increase the accuracy of the assessment and to satisfy the requirements of the EIS Guidelines.

4.2 Air quality and greenhouse gas Katestone Environmental Pty Ltd (Katestone) was commissioned to undertake a peer review on the air quality and greenhouse gas assessment of the Western Sydney Airport draft EIS. This section provides a summary of their review whilst Appendix C of this report Their review did not include a health risk assessment which was undertaken separately and presented in section 4.4 Human Health.

To assist with its review, access to all relevant input and output files that were integral to the air quality assessment studies was requested as this information was not contained in the EIS. The provision of such information is a routine expectation and is a minimum requirement of the NSW Environment Protection Authority (EPA) for such studies. For a peer review the data is integral to demonstrating the integrity of the assessment. However, this information was not made available and consequently, Katestone has relied only upon the information contained in the relevant chapters of the EIS to complete its review.

Where apparent errors and inconsistencies were found within and between documents, Katestone has noted these, but in most cases has not been able to discern the full significance of these on the assessment outcomes.

4.2.1 Overall comments on air quality study

The air quality study is contained in Volume 2 Chapter 12, Volume 3 Chapter 32 and Volume 4 Appendix F1 of the Western Sydney Airport EIS. It is noted that these documents contain many typographical errors and inconsistencies that undermine the credibility of the air quality assessment. These sections require a thorough technical and editorial review by its authors to address the issues outlined in this review to improve transparency and credibility of the air quality assessment. To enable confidence in the assessment, all information and data used in the emission estimation, model inputs and outputs should be made available to any interested party.



The air quality study did not adequately address the sensitive receptors as it:

Failed to identify all sensitive receptors;

Failed to identify a representative subset of sensitive receptors - whilst a small subset of sensitive receptors was identified, the subset does not appear to be representative of potential air quality impacts at all existing locations of sensitive receptors;

Did not identify future sensitive receptors; and

Incorrectly classified community receptors separately and as having a lesser importance than residential receptors. Community receptors included various land-uses such as schools, parks, childcare facilities, churches and shopping centres.

4.2.2 Stage 1 development

4.2.2.1 Local Air Quality

The assessment results are taken as presented in Tables F1 to F8 and Table G1 to G5 (Volume 4, Appendix F1) of the draft EIS, they indicate the following:

The maximum 1-hour average concentration of NO2 was predicted to exceed the EPA’s impact assessment criterion of 246 µg/m3 at one receptor. Three other receptors have maximum 1-hour average concentrations of NO2 that are 92% to 98% of the EPA’s impact assessment criterion.

The annual average concentrations of PM2.5 were rounded to one significant figure. A number of receptors were predicted to have an annual concentration of PM2.5 of 8 µg/m3 – equal to the Air NEPM Advisory Reporting Standard. These results are potentially indicative of minor exceedances (<0.4 µg/m³) of the Advisory Reporting Standard.

The 99.9th percentile 1-hour average concentration of formaldehyde was predicted to exceed the EPA’s impact assessment criterion at two receptors.

The predicted concentrations of all other air pollutants were below their respective assessment criteria.

The major contributor to elevated levels of air pollutants is aircraft emissions. However, for receptors close to existing or new roads, the major contributor is external roadways.

Mitigation measures were recommended. However, the effectiveness of the measures in achieving compliance was not quantified.

4.2.2.2 Regional air quality

The methods used to assess the regional air quality are acceptable. The assessment of regional air quality showed that only marginal increases in ozone concentrations would result from Stage 1 Development.

4.2.2.3 Greenhouse gases

The methods used to estimate greenhouse gas (GHG) emissions are acceptable. The estimates of greenhouse gas emissions are reliable and the contribution of greenhouse gas emissions from the project will be relatively small with Stage 1 Development emissions approximately 0.11% of Australia’s projected 2030 transport-related GHG inventory.



4.2.2.4 Overall comments

The Stage 1 Development assessment was based on the annual throughput of the airport would be 63,302 ATM in 2030. The stated maximum capacity of the airport following completion of Stage 1 is three times higher at 185,000 ATM in 2050. The local air quality assessment, regional air quality and greenhouse gas assessment all use this assumption in the generation of the emissions and resultant impacts. Consequently, the assessment has underestimated the potential impact of the Stage 1 Development by a considerable margin.

4.2.3 Longer term development

4.2.3.1 Local Air Quality

The assessment results are taken as presented in Tables F9 to F11 (Volume 4, Appendix F1) of the EIS, they indicate the air quality assessment of the Longer Term Development shows:

The maximum 1-hour average concentration of NO2 was predicted to exceed the EPA’s impact assessment criterion of 246 µg/m3 at 41 of the 96 receptors.

The maximum 24-hour average PM10 concentrations was predicted to exceed the EPA’s impact assessment criterion at three receptors.

The maximum 24-hour average concentrations of PM2.5 were predicted to exceed the NEPM Advisory Reporting Standard at three receptors.

The annual average concentrations of PM2.5 were rounded to one significant figure. The annual average concentrations of PM2.5 were predicted to exceed the Air NEPM Advisory Reporting Standard at 13 receptors (concentrations are reported as 9 µg/m3 or higher). A number of receptors were predicted to have an annual concentration of PM2.5 of 8 µg/m3 – equal to the Air NEPM Advisory Reporting Standard.

These results are potentially indicative of minor exceedances (<0.4 µg/m³) of the Advisory Reporting Standard.

Whilst a number of mitigation and management measures were listed within the Western Sydney Airport EIS, the effectiveness of the measures was not quantified and therefore the air quality assessment failed to demonstrate that compliance with the relevant air quality criteria could be achieved.

4.2.3.2 Regional air quality

The assessment of regional air quality showed:

The change in daily maximum 1-hour ozone concentration from the addition of the airport was 4.5 ppb which is significantly above the maximum allowable increment of 1 ppb defined in the NSW EPA’s tiered approach.

The change in daily 4-hour average ozone concentration from the addition of the airport was 3.7 ppb which is significantly above the maximum allowable increment of 1 ppb defined in the NSW EPA’s tiered approach.

However, the regional air quality assessment for the Longer Term Development is hypothetical as:

the impacts had to be assessed in context of the 2030 base case emissions as a base case inventory has not been projected for 2063;

changes in emissions to other existing sources had not been accounted for; and

assumes that the rail network exists.



4.2.3.3 Greenhouse gases

The methods used to estimate greenhouse gas emissions are acceptable.

4.2.3.4 Overall comments

The Longer Term Development contained in the Western Sydney Airport draft EIS includes a second runway, which relies upon the existence of rail services to be feasible. The Western Sydney Airport draft EIS states ‘As it is not possible for the longer term development to achieve the project passenger numbers without the rail network the traffic scenario that does not include the rail network was disregarded’.

Air quality associated with Stage 1 is critically dependent on the traffic volumes generated by the airport. Consequently, the impact on air quality due to the Longer Term Development is critically dependent on the existence of the assumed rail services to the airport. The Western Sydney Airport EIS is not seeking approval for the rail infrastructure that is necessary for its feasibility and the EIS does not contain a detailed proposal for the rail infrastructure. As a consequence, the air quality assessment of the Longer Term Development is speculative at best and does not provide a sufficiently robust basis to support approval of the Longer Term Development at this stage.

4.3 Traffic, transport and access

4.3.1 Approach

Arup has undertaken the peer review of the Traffic and Transport sections within the draft EIS. The peer review has been intended to assess the merits of the proposal as presented in the draft EIS – it has not been intended that the peer review will develop recommendations for alternative designs for the project.

In relation to Arup’s comments regarding any short comings of this assessment, it should be noted that Arup has not been privy to any specific requirements above and beyond those described in the Guidelines for the Content of a Draft Environmental Impact Assessment Statement, Western Sydney Airport, Environment Protection and Biodiversity Conservation Act, 1999. It is understood traffic and transport is likely one of the key environmental issues associated with the Airport. Arup has provided independent traffic and transport reviews relating to the adequacy of the documentation provided and the appropriateness of the mitigation measures proposed in:

‘Western Sydney Airport draft EIS 19 Volume 2 Chapter 15’

‘Western Sydney Airport draft EIS 39 Volume 3 Chapter 33’

‘Western Sydney Airport draft EIS Volume 4 Appendix J Surface transport and access’.


Issues identified in terms of predicted traffic impacts as a result of the Stage 1 airport include:

limitation of the strategic traffic model’s (STM3) ability to capture traffic impacts at a detailed level

detailed intersection traffic modelling not undertaken

intersection operations and performance not assessed

future land take impacts as a result of intersection operations

freight traffic generation and associated impacts (outside of specific air cargo) not assessed



traffic generation and associated impacts caused by the zoned lands within the Airport precinct not assessed

impact to public transportation operations (bus network) not assessed.

The above issues and limitations are considered significant. Further information would need to be provided to enable Arup to reach a firm opinion as to whether the conclusions reached in the study are valid. Until these comments are addressed or further information supplied, Arup is unable to comment on the validity of the traffic impact conclusions reached in this draft EIS.

4.3.3 Long term Airport development

The predicted traffic impacts of the long term development of the Western Sydney Airport largely followed the Stage 1 assessment. A number of the issues identified for Stage 1 are also apparent in the longer term development including:

limitation of the strategic traffic model’s (STM3) ability to capture traffic impacts at a detailed level

detailed intersection traffic modelling not undertaken

intersection operations and performance not assessed

future land take impacts as a result of intersection operations

freight traffic generation and associated impacts (outside of specific air cargo) not assessed

traffic generation and associated impacts caused by the zoned lands within the Airport precinct not assessed

impact to public transportation operations (bus network) not assessed.

Additionally, a number of issues identified in the longer term development (above and beyond Stage 1) include:

The local road network adjacent to the Airport reaches capacity by 2063. No road planning mitigation measures were provided.

Airport Access Drive (from M12) reaches capacity by 2050, 13 years before long term development year of 2063. Capacity is predicted to be reached for approximately 15 hours a day.

Insufficient information was provided to determine how air passenger demands would access and egress the Airport beyond 2050 (when the Airport Access Road reaches capacity).

No assessment was included to understand what impact the air passenger demands using the South West Rail Link extension (SWRLe) would have on the wider Sydney Rail Network.

Prior to the long term development of the airport being constructed, a major development plan (managed in accordance with the Commonwealth Airports Act 1996) will be required with final approval provided by the Minister for Infrastructure and Regional Development.

As such, Arup believes the above issues and limitations should be viewed in conjunction with this additional assessment being undertaken.



4.3.4 Key impacts and opportunities

The traffic impacts caused by Stage 1 of the Airport is predicted to be relatively low. With consideration to the methodology used, the draft EIS states the future road network is able to accommodate the predicted Airport traffic demand.

Nonetheless, it was difficult for Arup to confirm the validity of these impacts with confidence. Arup has identified further information that could be provided to quantify the potential impacts, including:

freight traffic generation within the Airport precinct (outside of air cargo)

private vehicle traffic generation from land uses within the Airport precinct (outside of air passengers)

vehicle travel time comparison (as predicted by strategic modelling)

intersection performance (as predicted by intersection modelling)

intersection layout requirements (as predicted by intersection modelling).

The following describes the predicted traffic impacts caused by the long term development of the Airport as described in the draft EIS:

The traffic impacts caused by the Airport is predicted to be significant. The airport Access Drive from the M12 is predicted to fail in 2050. This is approximately 13 years before the ultimate long term airport development year (2063).

The traffic impacts also affect the wider road network with significant congestion predicted on key road links in 2063. The assessment acknowledges this is a result of significant background growth in conjunction with unknown road infrastructure commitments past 2041.

The Airport also impacts wider transport modes. The assessment suggests additional rail link capacity (above and beyond the SWRLe) would be required to accommodate both the Airport trips and background growth trips by 2063.

With consideration to the above potential impacts, it is recommended that detailed transport network planning including road and rail network planning be undertaken.

4.4 Human health A peer review of the human health sections of the Western Sydney Airport draft Environmental Impact Statement (EIS) was undertaken by a team of international reviewers, led by the Centre for Health Equity Training, Research and Evaluation (CHETRE) at the University of New South Wales (UNSW).

4.4.1 Approach

The review team developed a peer review framework based upon existing best practice review guidelines for evaluating health impact assessment (HIA). The framework incorporated key elements, processes, and requirements that should be included in the health assessment of an EIS. Additionally, the review team reviewed existing HIAs of airport developments to establish the range of health effects that are relevant to airport health assessments. This framework allowed the review team to assess the quality of the health assessment that was included in the draft EIS, and also determine important health effects that were not included.



4.4.2 Limitations

The review team were only able to conduct a review of the health impacts included in the health chapters (Human Health Chapter and Community Health Appendix). These were limited to noise, air quality, and water impacts, therefore the review team were not able to further review the assessment of other potential significant health impacts associated with airport development, such as changes to employment, transportation, amenity, and housing.

Although the review team assessed the methods used we were not able to assess the validity of the calculations used in predicting health outcomes. Validity of the findings in the health risk assessment (HRA) were based upon what was included in the health appendix, which did not include all necessary methods and formulas to test the findings. It is assumed that the calculations were carried out correctly.

As there was not a comprehensive HIA included in the draft EIS, the review team were limited in the range of recommendations we could make.

4.4.3 Components of draft EIS Reviewed

Primary:

Part D – Human Health Chapter

Appendix G – Community Health

Secondary:

Volume 1:

– Executive Summary

– Part A – Project Background

– Part B – Airport Plan

Volume 2

– Chapter 9 – Approach to Impact Assessment

– Chapter 27 – Cumulative Impact Assessment

– Part E – Environmental Management

– Part F – Conclusions

Volume 3

– Chapter 39, Section 8 – Human Health

– Part H – Conclusion and recommendations

Volume 4

– Appendix E – Noise

– Appendix F – Air quality

– Appendix P1 – Social impact

– Appendix P3 – Economic analysis.



4.4.4 1st Stage Airport findings

Compliance with EIS Guidance:

Overall, the Health Chapters of the draft EIS comply with most of the EPBC Guidelines.

The impacts that are considered in the Health Chapters are those associated with changes in air quality, water quality and noise. Generally, these are assessed in detail in terms of nature and extent of short and long-term impacts.

Some of the information is presented in a way that makes it difficult for interested stakeholders to fully understand the scope and scale of the potential health impacts. The information provided is not always, clear, succinct and supported by maps or other accessible materials. Technical jargon is generally avoided without losing technical precision or the validity of the statements made. Cross-referencing is used however summaries of the findings of other chapters often do not fully explain key issues. Not all sensitive population sub-groups or receptors have been considered in the areas assessed.

The rational and justification for why a HRA has been undertaken rather than an HIA are not discussed. There is national and state level guidance on HIA that should have been consulted in the development of the scope and methodology of the health assessment of the draft EIS. Key guidance documents include Health Impact Assessment Guidelines (enHealth, 2001), and Health Impact Assessment: A practical guide (UNSW and NSWHealth, 2007). Ideally the health assessment would have used an HIA framework incorporating an HRA approach.

Ecologically sustainable development in relation to health is not considered. EPBC guidance states that ecologically sustainable development should ensure that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations.

Considering the most significant health impacts/effects/risks considered in the draft EIS are those related to changes in air quality, noise and water quality, the level of analysis and detail presented in the Health Chapters is reflective of the potential significance of these descriptors. However, the potential inequality/inequity impacts have not been sufficiently assessed or discussed. This is a significant gap.

Recommendations for the Health Chapters of the draft EIS to better comply with EPBC guidelines are provided:

The Health Chapters of the draft EIS should assess the health impacts/effects of changes in the full range of environmental and social determinants of health and the potential inequalities/equity issues due to the proposed development. The level of analysis and detail should be reflective of their likely significance. Examples are changes to road traffic movements and their potential health consequences (community severance, risk of road traffic accident and injury), changes in qualities and characteristics of the surrounding areas (including land values and other economic impacts) and changes in recreational use, amenity of natural areas and access to greenspace and nature and their associated health and wellbeing impacts through, for example, changes to levels of physical activity; effects on services and amenities.

Findings should be presented in a way that helps to communicate the scale of the population affected, by determinant of health, and also what the synergistic (combined) impacts are likely to be to various communities from exposure to the combined hazards.

Not all unknown variables, assumptions, and limitations are included in the assessment. A specific comment relates to certain health impacts (e.g. air quality-related health impacts on children, other chronic effects such as incidence of chronic bronchitis in adults) known to occur from exposure to air pollution but for which the level (extent/magnitude) of the health impact associated with a certain level of pollution exposure is uncertain or unknown. These additional health impacts, for which quantification is uncertain or unknown, are not discussed. The Health Chapters should consider and discuss health impacts where quantification is not currently recommended by national guidance (e.g. Australian Government Guidelines for Health Risk Assessment) such as air quality impacts on children, other



chronic effects, and other additional morbidity effects of short-term exposure but for which there is a widely acceptable evidence base supporting their likely occurrence.

Assessment of Air Quality:

The assessment of air quality-related health impacts follows a health risk assessment approach, focussing on quantification of health endpoints from exposure to a range of air pollutants. The methodology used is adequate. The range of air pollutants addressed is adequate. The range of health endpoints considered is also adequate and follows Australian evidence and guidance.

However, the range of health endpoints addressed could be expanded to include others for which solid exposure-response coefficients exist, for example, group A coefficients provided in the WHO HRAPIE Project report1.

It is also not clear what baseline incidence rates were used (Sydney average or Liverpool/suburb rates). If Sydney rates are used, this may have resulted in a small underestimation of risks.

Risks are estimated for 2030 and 2063 snapshots and separately for each pollutant. An overview of the expected scale of impacts resulting from the combined effect of all pollutants should be provided to provide a picture of the total risk to the exposed communities. It would also have been useful to include stage 1 predictions at full capacity (2050).

Risks could also have been provided for the entire assessment period e.g. 30 years and not just for the snapshots. Discussion of the uncertainty around estimates could be enhanced, for example through the use of the upper and lower 95% confidence interval values of the exposure-response coefficients used. This would provide a better understanding of the likely range of actual impacts (for the worst-case unmitigated scenario).

A general level of acceptability for estimated risks is used, stated to be accepted by regulatory agencies. This is for a risk between 1 x 10-6 (1 in a million) and 1x10-5 (1 in 100,000). The regulatory agencies should be named and references for this statement should be provided. Consideration should also be given to stakeholder perceptions of acceptability of risk.

There is no discussion of the implication of the distribution of effects for inequality and equity although baseline information on sensitive/vulnerable groups is provided.

Community feedback and any potential perceptions or concerns of local residents are not discussed. Community feedback on health concerns should be described and how this feedback was considered and addressed in the assessment should be discussed. Where community comments have not been incorporated or addressed an explanation justifying this should be presented. If there were no specific comments or concerns about health impacts/effects or some determinants of health then this should also be stated explicitly. There should also be a discussion of how communities were consulted.

Perception effects are different from biological or epidemiological risks, can cause stress and anxiety, and should be considered separately from mortality and morbidity effects.

Mitigation measures are not discussed, readers are cross-referred to the air quality chapter. An outline of proposed measures (i.e. an air quality management framework or plan) should be provided in the health chapter and an explanation provided for how and to what extent these measures will mitigate the identified health impacts.

1 Table 1. CRFs recommended by the HRAPIE project, p5–11



Assessment of Noise:

The assessment of noise-related health impacts follows a health risk assessment approach, focussing on quantification of health endpoints from exposure to a range of noise. The quantitative methodology used is adequate. The range of noise metrics used is adequate. The range of health endpoints considered is also adequate and follows Australian and international evidence and guidance, namely the enHealth Guidance Health Effects of Environmental Noise other than Hearing Loss (enHealth, 2004). Risks are estimated for 2030, 2050 and 2063 periods for three different operation phase scenarios.

A qualitative analysis and discussion of impacts/risks/effects on vulnerable/sensitive groups and on health inequality/equity issues has not been undertaken.

There is no discussion of the implication of the distribution of effects for inequality and equity.

Community feedback and any potential perceptions or concerns of local residents are not discussed. Community feedback on health concerns should be described and how this feedback was considered and addressed in the assessment should be discussed. Where community comments have not been incorporated or addressed an explanation justifying this should be presented. If there were no specific comments or concerns about health impacts/effects or some determinants of health then this should also be stated explicitly. There should also be a discussion of how communities were consulted.

Perception effects are different from biological or epidemiological risks, can cause stress and anxiety and should be considered separately from mortality and morbidity effects.

Mitigation measures are only discussed in passing and readers are cross-referred to the noise chapter. An outline of proposed measures (i.e. a noise management framework or plan) should be presented in the Health Chapters and an explanation provided for how and to what extent these measures will mitigate the identified health impacts.

Assessment of Water Quality:

A complete health risk assessment is not provided for water quality due to the limitations in water quality sampling (i.e. only 1997 data was available; no new data was collected for this EIS). A more complete assessment is required that includes a clear list of assumptions, a description of population affected, and an assessment of impacts on vulnerable receptor population groups.

Review of Overall Report:

The description of the context and requirements for the HRA are generally sufficient. It would have been advantageous to understand why only an HRA was undertaken and not a full HIA, considering that the Health Chapters recognize the significance of the social determinants of health. The population health profile was very limited in scope and is missing clarification for why only certain information is provided. Consideration of vulnerable populations is based around SEIFA scores only and again, it should be explained why only these scores, and not additional indicators of disadvantage are included. Any further information that is included in other chapters in the draft EIS should be referenced within the Health chapters.

Coverage of Health Topics:

The health risks described in the Health Chapter (air quality, noise and water) shows that some key determinants of health have been considered in reasonable detail. However, the potential inequality/inequity impacts have not been sufficiently assessed or discussed. This is a significant gap.

Some key determinants either do not seem to have been considered anywhere in the draft EIS or have not been considered and discussed in relation to health impacts in the Human Health Chapter and appendix. The approach taken to considering health impacts in the Health Chapters is narrow and does not take into account the findings of other health-relevant assessments, such as in the social impact assessment (SIA).



This has resulted in key environmental and social determinants of health not being considered. The scoping process whereby the decision to focus on air quality, noise and water is unclear so it is not possible to assess whether the narrow focus is justified. However given the current level of evidence on the effects of airports on health as well as the more general evidence base around the social determinants of health, it is likely that relevant health impacts are missing from the Health Chapters. The ‘non health’ sections of the draft EIS do however contain information about a number of significant impacts on the determinants of health (e.g. housing affordability, visual amenity). The majority of these relevant health determinants are covered within the SIA. These have not been identified as health impacts and the range and magnitude of potential health outcomes resulting from these impacts have not been assessed.

4.4.5 Long term development findings

The long-term development section (Chapter 39, Section 8) provides a summary of the long term health impacts that are discussed in more detail in the appendix. While the report does, at times, make reference back to the appendix, there is a lot of pertinent detail that is missing that should be referenced to the appendix. This section also lacks core components for clarity – such as discussing the methods used or mitigation measures - that would make this section acceptable as a standalone piece of work without having first read the appendix. This section also misses any discussion of long term cumulative impacts. Cumulative impacts are considered elsewhere in the report however this report does not make clear if the cumulative impact assessments were used in this assessment. It would be particularly relevant to include discussion of cumulative impacts here as there is no mention of health impacts in the cumulative impacts chapter. This section should also provide better characterisation of health impacts or otherwise provide a reference to where it is located in the appendix.


The Health Chapter contains predictions of the attributable health outcomes from air and noise exposures in communities near the airport. The majority of outcomes for air quality were below accepted thresholds, however there were some exceedances for Particulate Matter 10, Particulate Matter 2.5, and Nitrogen Dioxide. Impacts from noise were also mostly below standards, however, impacts varied widely for different communities, with Luddenham likely to experience the most impacts associated with noise. Sufficient data was not available to conduct a complete HRA for ground water and surface water, therefore there are no predicted health impacts.

The Health Chapter and appendix utilises a Health Risk Assessment approach. This is a quantitative methodology that takes changes to these environmental determinants and estimates their risk to health (i.e. the chances or risk of a disease or fatality occurring). This narrow approach does not address the full range of determinants of health and makes no use of the large evidence base on the association between health determinants, particularly social, and health outcomes.

There are two major weaknesses in relation to the assessment of health impacts that the review team strongly recommend be addressed in order to ensure that health effects are not overlooked or not taken into account when mitigation/enhancement is being considered. These are: the reporting of the identified health impacts; and the scope of the impacts included in the health chapter.



4.5 Aviation planning

4.5.1 Approach

The approach to aviation planning has been to review the four volumes of the draft EIS as well as the draft Airport Plan provided on the Western Sydney Airport website (www.westernsydneyairport.gov.au).

This review is based on a desktop study and a literature review of the four volumes of the draft EIS and the draft Airport Plan, comparison of these against the EIS guidelines, identification of potential opportunities or inconsistencies and a comparison against available benchmarks.


Issues identified in terms of aviation planning for the Stage 1 airport include:

Airport planning

No vocation or aviation purpose is described for Western Sydney Airport.

There is a degree of variability in the forecasts and demand information used in the draft EIS and draft Airport Plan. In addition, the forecast passenger loads per aircraft for Western Sydney Airport as presented in the draft EIS appear to be high.

It is unclear what benchmarks or planning decisions sit behind the 1900m runway separation shown for Western Sydney and it is noted that other airports in Australasia are proposing wider runway separation.

Benchmarking indicates that passenger throughput per aircraft stand is potentially high for Western Sydney Airport. This would imply that the number of aircraft stands shown is less than one might typically expect.

Airspace and flight tracks

The proposed airspace model is noted as a “proof of concept” and not the subject of exhaustive analysis. This indicative airspace design was not developed with consideration to potential noise or other environmental impacts.

A single airspace model is presented for Stage 1 development. The basis of the model is that operations at Sydney Kingsford Smith Airport are unaffected. Other than minor flight path displacement, feasible alternatives are not presented or evaluated. However, presenting alternatives is a requirement of the EIS guidelines provided by the Department of Infrastructure and Regional Development.

Departures track to 'exit gates', concentrating aircraft on several defined routes. This is a common tool used to improve air traffic flow. The impact of concentration and location of turn points has not been tested for environmental impact.

Modes of operation (flight paths based on runways in use) are mentioned, but not how they affect surrounding areas.

Noise abatement procedures, commonly implemented at other major airports, have not been developed.

Bird and bat strike

The bird and bat strike assessment concludes that the overall risk for the airport is low. However the assessment is preliminary.



Fuel dumping

Fuel dumping is concluded to be low risk and it is considered that the information presented in the draft EIS is appropriate.

4.5.3 Long term development

A number of the issues identified for Stage 1 are also apparent in the longer term planning of Western Sydney Airport.

The lack of vocation or purpose for Western Sydney Airport and its relationship to the ongoing operation at Sydney Kingsford Smith Airport and, in particular, that potential long-term growth forecasts are very high.

The variability in the number of stands and the apparent lack of consistency in terms of a base set of planning parameters used in developing the airport.

Narrow runway separation to achieve all the proposed aviation uses.

Lack of a full and thorough assessment of the interaction of aircraft traffic in the Sydney Basin which requires an airspace and flight path review not considered as part of Stage 1. The Stage 1 flight paths proposed in the draft EIS are not considered appropriate for the long term plan.


Key impacts and opportunities from an airport planning perspective for the above issues are as follows:

Vocation or purpose of Western Sydney Airport – One might expect that, certainly in its early stages of development, the Western Sydney Airport would potentially be a predominantly domestic, low-cost carrier airport with a significant cargo operation, reflecting lower charges and the lack of noise curfew. Premium international flights would continue to use Sydney Kingsford Smith as the primary airport in New South Wales and the one which provides proximity to the tourist and business centre of Sydney CBD. This vocational aspect is important in influencing how the future airport will operate, peak periods of activity and the type of traffic that will use the airport.

Forecasts – There is potential that the forecasts understate the number of aircraft movements required, which has knock-on impacts on dependent analysis such as noise modelling. This is a potential area for further assessment or clarification to confirm that findings in the draft EIS and draft Airport Plan based on these forecasts are robust.

Runway separation – Any wider runway spacing would increase land take, with downstream environmental impacts on biodiversity, surface water and groundwater, landscape and visual amenity. In addition, wider spacing for the future two runway airport will impact on flight tracks and noise given changes to runway thresholds.

Aircraft stand provision – The number of aircraft stands shown is potentially less than one might typically expect, which has implications for land take and therefore related environmental impacts, though it is noted that the Land Use plan for Stage 1 shows a large area available for development.

Airspace, OLS and PANS-OPS – In terms of requirements, the evaluation of protection volumes for flight paths and airspace containment is in accordance with normal methods mentioned in the Airports (Protection of Airspace) Regulations and under the Airports Act 1996. Whilst analysis of Obstacle Limitation Surfaces (OLS) and Instrument Flight Procedure protection volumes (known as PANS-OPS surfaces) indicates that, operationally, the Western Sydney airport can operate unrestricted from terrain and artificial obstacles.



However, the following impacts are identified which are either unresolved or which require further clarification:

1. The proposed airspace architecture is 'indicative' and has not been rigorously tested. The draft EIS proposes that another airspace model is tested closer to commencement of operations.

2. Flight paths appear to fly over water storages such as Warragamba Dam and Prospect Reservoir. The environmental impact is unclear.

3. The requirement under the Guidelines, produced by the Department of Infrastructure and Regional Development (DIRD), for feasible alternatives to be included has not been met. This is particularly important in consideration of concentration of approaching traffic over the township of Blaxland for the Stage 1 development and departure tracks.

4. There is no consideration of community sentiment regarding changes to flight paths, proposed in the draft EIS, when the Airport operates with two runways.

5. An alternative Stage 1 airspace model, based on the long term proposal but operating with a single runway, is not tested.

6. Except for Sydney Kingsford Smith, flight paths for aerodromes, affected by the Western Sydney Airport are not evaluated.

7. The draft EIS suggests that Western Sydney Airport will detrimentally affect the operations at Bankstown and Camden, and affect Richmond (military). The environmental impact is not quantified.

8. Relocation of light aircraft traffic to other airports, the definition of new training airspace and consequent environmental impact, is not assessed.

Given the above, it is considered that the information on airspace presented in the draft EIS does not meet requirements.

Bird and bat strike – the bird and bat strike assessment is preliminary and therefore further works in the airport site and study area are required to confirm the level of bird and bat strike risk and to refine the mitigation strategies, in parallel with design development.

Fuel dumping – It is considered that the information presented in the draft EIS is appropriate.

4.6 Social and Economic

4.6.1 Approach

In undertaking this review we have had particular regard to the requirements established by Section 10 of the Guidelines for the Content of the Draft EIS – Western Sydney Airport issued in January 2015 by the DoE.

We have also considered the implications of both the Stage 1 Airport and longer term development with regards to:

Potential gaps in the preparation of the Social and Economic Specialist Studies;

Any concerns regarding the validity of assumptions and conclusions; and

Suggestions to improve the effectiveness of the proposed mitigation measures.



4.6.2 Components of the draft EIS reviewed

The following components of the draft EIS have been reviewed in relation to Social and Economic impacts:

Relevant sections of the Executive Summary

Volume 2—Stage 1 development – Chapters 23 and 24 – Social and economic

Volume 3—Long term development – Chapter 37

Volume 4—Specialist studies in appendix P1, P2 and P3.

The social and economic review support the draft EIS’s summation that the main benefits of the Western Sydney Airport relate to the generation of jobs in Western Sydney and associated economic activity. The importance of this contribution to Sydney represents an important policy shift since the preparation of the earlier EIS’s for a second airport on the site as Western Sydney has become a greater focus for economic growth and activity.

In drawing this conclusion however we maintain the need for a balanced assessment across positive and negative social and economic impacts, both at a local and regional level, over the short and longer term. To this effect six overarching issues have been identified in relation to the current draft EIS and its assessment of impacts during Stage 1 of the Airport and a further four regarding its assessment over the longer term as discussed on the following pages of this Executive Summary.


4.6.3.1 Balance of discussion – Impacts

We identify a strong focus in the EIS on the economic benefits of Stage 1 of the Western Sydney Airport as distinct from a balanced discussion of economic and social costs and benefits. For example the economic Chapter (24) in Vol. 2 focuses entirely on the regional (Western Sydney) and broader (Sydney, NSW and Australian) employment and economic benefits of the Western Sydney Airport with only one general reference to potential adverse economic impacts as follows.

‘However there would be some negative impacts in the immediate vicinity of the airport site due to combination of the airport development and the changing land uses’ Vol. 2, Chapter 23, Pg. 504

A more balanced discussion of costs and benefits is therefore encouraged. For example in relation to matters such as impacts to local business activity during construction or the potential impacts of a new business park (with retail as a permissible use) to existing and proposed centres in the South West (i.e. Leppington, Edmondson Park and Liverpool).

4.6.3.2 Balance of discussion – Geography

Our comments regarding the balance of discussion also relate to the EIS’s strong focus on the regional and Australian economic benefits of the Western Sydney Airport as distinct from any prospective local impacts. For example the economic benefits and costs to centres within close proximity to the Western Sydney Airport (i.e. Luddenham or within the South West Growth Centre) are little, if at all discussed. Whilst the impacts may be positive or minimal, it is appropriate that they are considered and where possible quantified.

4.6.3.3 Translation of issues within the EIS

The Specialist Social Impact Study in Appendix P identifies a number of likely adverse impacts to the local communities. Despite the significance of these impacts and their potential to raise notable social concerns,



many are given relatively minor reference in the relevant Chapter (23) with no reference in the Executive Summary.

This results in an ill-informed view of social issues for readers of the EIS who may not progress to read Chapter 23 or Appendix P in detail.

4.6.3.4 Statements without assessment

In the Stage 1 social and economic chapters (23 and 24) many of the potential issues are stated with little assessment of their implications to communities, their degree of significance or duration and alternative approaches that may be applied to alleviate them. For example the provision of alternative open spaces to communities during the construction process, the severity of noise impacts to recreational areas, the degree of noise disturbance for different locations over the short and longer terms.

This approach weakens the appreciation of the issues and the means to mitigate them. It could also result in greater angst by the community as to the likely degree, duration and severity of impacts.

4.6.3.5 Direct response to Stakeholder Engagement

The initial stakeholder engagement programme for the Western Sydney Airport identified a range of social and economic concerns (Vol.1, Chapter 8). A number of these concerns are listed by the specialist studies yet are not specifically addressed by Vol. 2 or 3 of the EIS. Furthermore the consultation chapter (Vol 1, Chapter 8) refers to an EIS summary paper being prepared however it is understood that this paper was not made available.

It is recommended that a summary consultation paper is prepared and made publically available and that each issue raised by stakeholders is considered and responded to by the specialist studies. In turn the body of the EIS should identify the most appropriate mitigation measures and minimise community concerns.

4.6.3.6 Transfer and redistribution effects

Much of the draf EIS’s discussion regarding the economic value add as a consequence of the Western Sydney Airport recognises its ‘….role in attracting economic activity to the Region’ at the expense of others i.e. ‘There is a reduction in value-add in the Rest of Australia’ (Pg. 139) and ‘The model assumed the future regional employment growth would be redistributed across Sydney…’ (Pg. 141).

Whilst the generation of jobs in Western Sydney is a strong positive of the Western Sydney Airport, the draft EIS does not discuss the economic or social implications of this transfer of activity from the other areas in Sydney or ‘the rest of Australia’. Whilst any such impact might be negligible or acceptable, the potential impact should be recognised and considered in the assessment.


The longer term assessment of impacts by the EIS is generally an extension of those identified upon operation for Stage 1. Our review finds that if left unmitigated, these impacts would generally be exacerbated on account of the significant increase in flights and passengers owing to the introduction of the second runway.

Key issues relate to:

9. How potential social and economic impacts could be managed and mitigated with such a significant and relatively quick increase in the number of passengers and associated on site employment (+120%) over the 13 year period between 2050 and 2063;



10. The potential impact of additional flight paths and operations to regional amenity and the impacts to the longer term development potential of affected areas in Western Sydney and more specifically in the South West Growth Centre i.e. height and noise restrictions to increasing residential density;

11. The degree to which the Western Sydney Airport could ‘…lead to the reduction in social amenity and impacts on the existing lifestyle of people living and working….’ (Pg. 138) identified by the EIS; and

12. The economic costs or implications of the Western Sydney Airport’s ‘….role in attracting economic activity to the Region’ at the expense of others i.e. ‘There is a reduction in value-add in the Rest of Australia’ (Pg. 139).

4.6.4.1 Mitigation of Longer Term impacts

A review of the discussion concerning mitigation measures over the longer term focuses heavily on planning mechanisms (i.e. zoning of land to exclude residential uses) together with local and State Government investment to address broader traffic, transport and infrastructure issues.

There is no discussion, however, of how this would be co-ordinated or resourced to address specific impacts resonating from the Western Sydney Airport. Further there is no discussion as to who the key accountability would fall with.

This results in a potential risk that some mitigation measures and impacts would be missed or forgotten over time.

4.6.4.2 Setting a framework for further assessment

To improve the longer term assessment and give some comfort to its approach, we suggest:

Further assessment of the potential social and business impacts and the information gaps with some parameters or ranges of assessment; and

The identification of the main body responsible for managing and mitigating these impacts and risks over time or how the mitigation framework will be managed.


A review of the EIS has identified the following potential impacts and opportunities during Stage 1 and over the long term development.

Table 4.1 Summary of impacts and opportunities

Stage 1 Longer term

Impacts Social Improved employment opportunities

Reduced travel time to work opportunities

Increases in average wages

Improved retail and business service choice and price competition

Changes to semi-rural lifestyle

Changed access to spaces and community facilities on the Western Sydney Airport site

Impacts to community cohesion

Impacts to social service provision

Social Improved employment opportunities

Reduced travel time to work opportunities

Increases in average wages

Improved retail and business service choice and price competition

Impacts to social service provision

Amenity and health impacts (noise, visual and air quality) owing to airport operation



Stage 1 Longer term

Perceived impacts and associated social anxiety

Amenity impacts during construction (dust, noise, road closures)

Amenity and health impacts (noise, visual and air quality) upon operation

Housing affordability

Economic Construction jobs

Multiplier benefits of operational job generation

Economic value add for the economy

Increased customer base and business activity

Redistribution of jobs to Western Sydney

Local business impacts during construction and operation

Land value changes

Impact to retail and center viability

Changes in traffic congestion

Congestion impacts to WSEA and local and regional roads

Decline in agriculture industries

Economic Multiplier benefits of job generation

Agglomeration benefits for Western Sydney businesses

Economic value add for the Western Sydney economy

Redistribution of jobs to Western Sydney

Improved appeal of investing and operating airport related businesses in Western Sydney

Land value changes

Impact to retail viability and opportunities

Opportunities Greater population growth and diversity (age and socio-economic) owing to employment opportunities

Improved live/work connections

Potential increase in tourism in the Blue Mountains

Greater appeal of Western Sydney to business and investment

Continued population growth and improvements in social diversity

Improved balance of economic outcomes across Sydney

Improved balance of social and community outcomes

Enhanced local, Sydney and Australian economies

Key: Positive impacts, negative impacts/opportunities, neutral or positive impacts/opportunities dependant on stakeholder

4.7 Surface water and groundwater

4.7.1 Approach

Cardno have undertaken a desktop review of the draft EIS documents and have assessed the draft EIS with respect to the following items:

An evaluation of whether the ground and surface water studies meets the requirements of the EIS Guidelines and relevant other guidelines and methodologies;

An evaluation of whether the conclusions reached in the studies are valid;

An evaluation of whether the underlying assumptions used to inform the assessment are plausible and credible;

A review of the mitigation and management measures proposed and advice provided on their likely adequacy in mitigating impacts;



An evaluation of the level of uncertainty over impacts and the environmental risks that will arise as a result of the project; and

A summary of the key impacts and opportunities associated with the project in relation to the Surface water and groundwater studies.

Descriptions of methodologies and impacts have been cross-referenced across chapters and the technical reports and figures checked for whether they aid understanding. Limited spot checks on values presented in tables have been undertaken together with applying sanity checks to data and model results with expected outcomes.

Surface water and groundwater have been reviewed by separate specialists, except where there is an inter-connection between the two, such as with water quality.

Prior to release of the draft EIS, Cardno initially reviewed available background documents to gain an understanding of site settings and project history including EPBC documentation and the 1997–1999 draft EIS by PPK.

4.7.2 Limitations

The following limitations apply to the review of the surface water and groundwater:

No site visit has been undertaken;

No numerical models were available and hence no review of models or inputs has been undertaken other than what has been reported, nor have any models been run as part of the review;

No data is available for review and assessment is limited to commentary on the data provided, however, data gaps have been identified;

Cardno assumed the data used for the impact assessment had gone through a quality control process before use and therefore can be relied upon; and

Similarly Cardno did not review the interpretation of the data, for example the attribution of a bore to a specific aquifer.

4.7.3 Components of the EIS reviewed

The following components of the draft EIS have been reviewed in relation to surface water and groundwater:

Volume 1—Project Background:

Executive Summary

Part A— Project background

Part B— Airport Plan

Volume 2—Stage 1 Development:

Part D — Environmental Impact Assessment:

– Chapter 9: Approach to impact assessment

– Chapter 17: Topography, geology and soils

– Chapter 18: Surface water and groundwater

– Chapter 27: Cumulative impact assessment

Part E— Environmental Management



Part F —Conclusions

Volume 3—Long Term Development:

Part G — Assessment of Long Term Development

– Chapter 30: Approach to impact assessment

– Chapter 34: Surface water and groundwater

– Chapter 39: Other environmental matters

Part H — Conclusion and recommendations

Volume 4—EIS Technical Reports

Appendix C: Western Sydney Airport EIS Guidelines

Appendix L:

– L1 Surface water hydrology and geomorphology

– L2 Surface water quality

– L3 Groundwater.

4.7.4 Stage 1 airport

A summary of the assessment of compliance of the draft EIS with the EIS guidelines is provided in Table 2-1. In general the elements of the EIS Guidelines have been addressed, however, some gaps have been identified in the assessments.

Primarily, comment on how the reliability of the information was tested and what uncertainties (if any) are in the information is not presented. Further, figures and maps are provided, however, many figures and maps are not clear and could be improved to aid understanding. Mitigation and management measures are identified, however, are generally broad and do not necessarily target specific residual impacts or propose specific measures or targets.

The review has also identified some technically incorrect statements made in the EIS, however, Cardno has assessed that consequences for the outcomes of the impact assessment are limited.

4.7.4.1 Surface water

The overall outcome of the impact assessment is that there are minimal impacts to surface water, geomorphology and water quality as a result of the Stage 1 development including appropriate mitigation measures. Some specific residual impacts are noted in relation to changes to water level and geomorphology at Oaky Creek and on a tributary of Badgerys Creek.

The identified gaps in the assessment relate to:

Flooding – Residual impacts in Cosgroves, Oaky and Badgerys Creek are identified. Cardno agree that the impacts may be relatively minor if the results as presented are correct. However, it is difficult to confirm whether the statements and conclusions are valid as there is a lack of supporting information and presentation of inputs and results are not clear and concise. Further, these impacts still require management to mitigate them to negligible levels.

Duncans Creek and its tributaries have not been modelled to allow definition of baseline and relative hydraulic impacts in these locations. Such impacts have been assessed by the changes in the hydrology for these catchments. As such, all summary impacts do not fully consider impacts to the Duncans Creek downstream areas. Investigation of a basin at this location is proposed as a mitigation/management measure.



Many of the figures/maps provided in both the main chapters of the EIS and in the technical reports are either not easy to understand or omit relevant information to aid ease of understanding.

Cumulative impacts have been discussed, however, no assessment has been undertaken to quantify the potential impacts other than for climate change scenarios.

Water quality has not been presented in terms of achieved pollutant load reduction or assessment against guideline pollutant reduction targets. The EIS seems to dismiss any relevance of increased pollutant loads on the receiving environment and instead determines that impacts are acceptable because there are general improvements in pollutant concentrations due to increased flow volumes.

The EIS discusses the tributary of Badgerys Creek that joins Badgerys Creek approximately 300 metres downstream of Elizabeth Drive under existing conditions. It acknowledges that threatened ecological communities have not been mapped outside the site as part of the biodiversity assessment, but there is evidence of some remnant native vegetation along this reach of creek, which would be reliant on occasional flooding and would be impacted under the current proposals. Such impacts need to be assessed to ensure there are no impacts and any mitigation and management measures identified.

Surface water impact management is required to address the following residual risks to surface water:

Outstanding localised increases to flood depths in Cosgroves, Oaky and Badgerys Creeks.

Risks to erosion and geomorphological changes to the downstream creeks due to increases in bed shear stress at various locations.

Undefined impacts and mitigation for runoff to Duncans Creek.

Implications of increases in pollutant loads, particularly for cumulative impacts are not addressed.

Ecological impacts in receiving waters are not clearly addressed.

Impacts of potential use of stormwater to provide water supply for site preparation works has not been considered.

4.7.4.2 Groundwater

The overall outcome of the impact assessment is that there would be no impact to groundwater systems and associated values due to the presence of tight clay soils and limited groundwater presence directly below the site. Cardno does not concur fully with the assessment, this difference results from a key assumption made in the EIS by characterising the uppermost aquifer.

The identified gaps in the assessment relate to:

Groundwater values are identified, however the groundwater dependent ecosystem lacks characterisation and conceptualisation with respect to water source.

Sufficiently complete characterisation of the weathered rock (regolith) aquifer is not provided. For example, the aquifer composition, nature and thickness distribution is unknown (this could have been collated through a review of all drilling logs performed on site overtime), and the level of saturation of the aquifer is also unknown. This is a limitation in understanding the connectivity of the weathered rock (regolith) aquifer to the alluvium aquifer supporting groundwater dependent ecosystem.

Similarly, no baseline time-series data has been collected. This is especially a limitation when it comes to characterisation of the weathered rock (regolith) aquifer and the contribution of this aquifer to the alluvium formations along the creek lines where groundwater dependent ecosystems are primarily located.

The impacts are reasonably well identified, however some of the impact assessment is missing a clear outcome statement.



Impact management and mitigation measures are only discussed generally with potential mitigation measures to be considered and monitoring to be implemented. Groundwater impact arising from contamination is suitably addressed. Groundwater impact arising from the development of the site is, in view of the lack of information on the uppermost aquifer, inappropriate especially when addressing impacts on groundwater dependent ecosystems.

Consideration of groundwater recharge is discussed at length for the Bringelly Shale and overlying aquifer, however, the discussion does not extend to the alluvium aquifer.

Groundwater management is required to address the two residual risks to groundwater values:

Risk of soil and subsurface contamination from spill/release of chemicals or contaminants. A discussion is suitably provided to this effect in the EIS documents. Cardno agrees that the details of the management program cannot be defined at this stage and should be incorporated in a site environmental management plan.

Risk of impact on groundwater dependent ecosystems from reduced water supply to the creek alluvium system. In Cardno’s view, the EIS documents do not provide a robust impact assessment of the risk to the Cumberland Plain Woodland along Badgerys Creek. Cardno suggest that the following management and mitigation approach could be considered to address the EIS guidelines requirements:

implementation of baseline data acquisition with an aim to document the contribution of recharge to the creek alluvial system from the weathered rock (regolith) aquifer, the Bringelly Shale and streamflow;

a review of the risk to the ground water dependent ecosystem; and

based on the outcome of the previous item, the management and mitigation will vary with the level of risk. A risk propagation based monitoring strategy and response plan may be suitable. In this case, a response plan would propose a suitable early warning indication of impact propagation and provide the management and mitigation measures if necessary to prevent adverse impact. If the risk is identified to be more significant, engineered solutions may need to be considered in the site design. Another management and mitigation solution could involve inputs into site design to prevent impact on streamflow and indirectly aquifer recharge or mitigate the loss of recharge.


4.7.5.1 Surface water

For the long term development, the impact assessment builds on the assessment for Stage 1. The hydrologic, hydraulic and water quality models used in the assessment include representations of the drainage system incorporated into the concept design of the indicative long term development.

The concept design of the long term development includes expanding the drainage system to control the flow of surface water. An extension of the Stage 1 detention basins is proposed together with provision of an additional detention basin in the longer term.

The following risks to surface water for the long term development and their implications have been identified:

Outstanding localised increases to flood depths in Cosgroves, Oaky and Badgerys Creeks.

Risks to erosion and geomorphological changes to the downstream creeks due to increases in bed shear stress at various locations.

Undefined impacts and mitigation for runoff to Duncans Creek.

Implications of increases in pollutant loads, particularly for cumulative impacts are not addressed.



Ecological impacts in receiving waters are not clearly addressed.

Impacts of potential use of stormwater to provide water supply for site preparation works has not been considered.

It is believed that most of the above issues can be addressed through refinement of the drainage strategy to manage flows, velocities and water quality. There are some outstanding impact assessments which have not been considered and should be addressed such as ecological impacts, use of stormwater for construction and impacts on Duncans Creek.

A reasonably robust assessment of the long term development has been undertaken. There is no formal framework for further assessment established as part of the EIS. The EIS for the Long Term Development simply lists considerations for future development as part of future design stages to address the impacts to be minimised. While this list identifies some of the key items to be addressed, in does not recommend any specific measures or processes that must be adhered to so as to tie those activities back to this EIS and associated approvals.

4.7.5.2 Groundwater

The following risks to groundwater for the long term development and their implications have been identified:

Risk associated with change of land use and decrease of groundwater recharge. The implication is possibly, a lack of groundwater supply to the groundwater dependent ecosystems (EPBC listed). If the studies highlighted in the data gap analysis confirm that there is a risk, an artificial groundwater supply scheme to the alluvial aquifer or designed streamflow release upstream of the ecosystem will possibly be required to support aquifer recharge. If the studies identify that there is no risk of impact to the groundwater dependent ecosystem water supply, then no further work will be required.

Risk associated with the possible use of chemicals over irrigated areas. The level of risk will depend largely on locations and practices. The implication is possibly an impact to the health of groundwater dependent ecosystem through runoff and infiltration in the alluvial aquifer. Management of this risk implies best practices be followed for the use of fertilizer and pesticides, additionally, targeted analytes could be included in groundwater monitoring.

Risk associated with the use of groundwater as a supply. A groundwater assessment will be required to establish whether the extraction of the required volume is feasible and the impact on nearby groundwater users. It should be noted that the target aquifer will be the deeper Hawkesbury Sandstone. The implications in terms of work required will depend on the volume required. At most, the studies for a groundwater assessment are likely to require the drilling of a few wells (at least one observation and one pumping well), pump testing and analysis and some groundwater modelling.

The EIS identifies some of the required assessments and activities especially in relation to water quality management. The EIS also identifies that additional assessments will be required would the project require to use groundwater as a water supply. However, the EIS did not identify the state and federal regulatory processes likely to be required for the management of the site groundwater values (liaison, review and approvals, licences for example), nor did it clearly identify the management plans and response plans required to be in place. The EIS did not identify assessment remaining to be performed to collect baseline data and confirm the hydrogeological conceptual model.


Key project impacts and opportunities are as follows:

Localised increases in flood depths are indicated at a number of locations.



Impacts in Duncans Creek are not fully considered and additional modelling would be required to determine residual impacts and any proposed management measures.

Potential erosion and geomorphology changes with increased flow volumes and isolated increases in be shear stress.

Increased pollutant loads for total suspended solids and nutrients, although pollutant concentration are equal or reduced compared to existing.

Impacts on the groundwater dependent ecosystem associated with Badgerys Creek are not fully identified due to a lack of characterisation of the alluvium aquifer and in particular of:

The relationship between the alluvial aquifer and the weathered rock (regolith) aquifer; and

The characterisation of the recharge of the alluvium aquifer.

These groundwater dependent ecosystems are declared a Matter of National and Environmental Significance under the EPBC Act. A review of the groundwater conceptual model would be required to enable characterisation of impacts on the Badgerys Creek groundwater dependent ecosystem.

There is an opportunity to improve the outcomes of the EIS to manage the residual impacts through refinement of the drainage strategy and management plans during future detailed design stages. It is recommended that the residual impacts are clearly defined in the EIS and appropriate specific management measures and targets be proposed or specified to ensure that these issues are addressed.

Given the complete redevelopment and earthworks taking place on site, there is opportunity to introduce even higher levels of stormwater management and water quality treatment to further minimise the impacts of the project and potentially improve the outcomes. This would assist in minimising cumulative impacts on the environment that may occur in combination with the surrounding South West Growth Centre and Western Sydney Employment Area development impacts.

With respect to groundwater impacts, there is an opportunity before site activities to acquire suitable baseline data and review the level of risk to the groundwater dependent ecosystem along the creeks. There is also an opportunity to define site design requirements to ensure recharge of the alluvium aquifer and, consequently, preservation of Badgerys Creek groundwater dependent ecosystem.

4.8 Greater Blue Mountains

4.8.1 Approach

This section of the draft EIS review focuses on the potential impacts of the proposed airport on the Greater Blue Mountains Area (GBMA). The Greater Blue Mountains are listed as a National Heritage place and as a declared World Heritage property. As such, this review takes into account the following matters of national environmental significance outlined in the EIS guidelines:

the heritage values of a National Heritage place

the world heritage values of a declared World Heritage property.

4.8.2 Components of draft EIS reviewed

The potential impacts of the proposed airport on the Greater Blue Mountains are addressed in Chapters 26 and 38 of the draft EIS. Technical reports for noise, social, biodiversity and air quality consider the Greater Blue Mountains as a sensitive receiver in the detailed assessments.



4.8.3 Findings

4.8.3.1 First stage airport

Chapter 26 of the Western Sydney Airport EIS draws on information from the environmental and social assessments undertaken for the first stage airport on the World Heritage and National Heritage values and other values of the Greater Blue Mountains World Heritage Area (GBMWHA).

The methodology applied to the assessment World Heritage, National Heritage values and other values included:

identification of the property’s World Heritage and National Heritage values, including attributes recognised in the Statement of Outstanding Universal Value;

identification of key examples or attributes of other values that complement the property’s World Heritage and National Heritage values;

collation of relevant baseline information on environmental factors and existing impacts including baseline noise levels and flight paths associated with Sydney Airport;

assessment of significance of impacts on World Heritage values and the integrity of the world heritage property and the National Heritage values based on the Significant Impact Guidelines 1.1 (DoE 2013a) and the property’s Statement of Outstanding Universal Value; and

assessment of the National Heritage area having regard to all environmental matters.

The draft EIS assessment of the potential impacts was limited to noise, air emissions and amenity impacts from overflight of aircraft, lighting and traffic.

The GBMA comprises eight protected areas. The GBMWHA Strategic Plan (DECC, 2009) provides a framework for the integrated management, protection, interpretation and monitoring of these areas. Each park has a Plan of Management prepared by the NSW National Parks and Wildlife Services which provides the detailed management prescriptions for each reserve which have not been included in the draft EIS.

4.8.3.2 Compliance of the report with the (EPBC Act) EIS Guidelines

As the GBMA is listed as a National Heritage place and a declared World Heritage property, this review assesses compliance with the sections of the EIS Guidelines that relate to the requirements of controlling provisions (5(a), (d), 6(a), 6(b), 6(c)(ii), 7(a)) or MNES (5(c)) or make specific reference to the GBMWHA (4(b), 5(g) and 6(b)(e)).

Table 4.2 Compliance of draft EIS with EPBC Act Guidelines

EIS Guideline EIS Section Comment

4 Description of the environment

Description of the GBMWHA world heritage values.

26.3.2 Description of the world heritage values adequately reflect the UNESCO 2015 information.

Description of the GBMWHA national values.

26.3.3 The area and values of the GBMA are the same as the World Heritage Area so the EIS uses one assessment to address both sets of values. Peer review of the EIS confirms the Greater Blue Mountains Area meets the official values of criterion a, b, c and d due to meeting world heritage criterion ix and x and therefore one assessment is considered adequate.



EIS Guideline EIS Section Comment

Reference to World Heritage criterion.

26.3.2.1 Reference to World Heritage criterion ix and x in Chapter 26.

Reference to the integrity of the property.

26.3.2.2 Reference to the integrity of the GBMA discussed in Chapter 26 and reflects the world heritage listing.

5 Relevant impacts:

construction, operation and decommissioning phases

facilitated impacts on MNES

justification for no impact.

26.4 Construction impacts mentioned but none identified that would affect the values of the GBMA due to distance and lack of direct connectivity this is a valid justification.

26.5 & 38.3 Direct and indirect operational impacts discussed. Indirect impacts associated with noise, air quality and amenity.

Facilitated impacts from increased tourism and associated economic development.

Decommissioning impacts have not been discussed assessed, given that the likelihood of the airport being decommissioned is low this project phase is not considered relevant.

6 Avoidance and mitigation measures

Take into account relevant agreements and plans that cover impacts or known threats.

26.6 & 38.4 Influence on existing threats (26.5.5 & 38.3.5).

GBMWHA Strategic Plan forms the basis of the other values and existing threats. It is noted that there are other management plans that cover the individual parks in the GMBA that have not been included in this assessment.

7 Residual impacts and offsets - Residual impacts have not been discussed for impacts on the GBMWHA.

Noise

The technical noise report provides an assessment of noise levels in the Greater Blue Mountains World Heritage Area (GBMWHA). To provide a basis for assessing impacts to the GBMWHA, the technical noise report presents information in the form of track density plots. While this form of data provides a useful and established form of information, the reason for reverting to overflight numbers in lieu of predicted noise levels is not stated. As per the discussion in section 2.3.2, this may be related to increased uncertainty in the predictions when considering low predicted noise levels. However, flight track density plots in isolation do not illustrate the full extent of potentially intrusive noise levels at locations to the side of the flight track.

The report notes aircraft are typically at an altitude of approximately 5000 ft, which corresponds to a noise level on the ground of approximately 55 dB LAmax, consistent with INM predictions for the Airbus A320 or Boeing 737-800. Measurements at other airports have however demonstrated that aircraft at that altitude are generally higher than those predicted using the INM, and accordingly noise levels in practise could be higher.

The assessment of noise impacts in tranquil areas is complex and guidance on the subject is limited. As per the technical noise report, levels below 55 dB LAmax could be considered intrusive by recreational visitors and other users. The natural soundscape in terms of sound press levels and sound characteristics are important attributes of high value wilderness areas. While levels below 55 dB LAmax are likely to be comparable to typical levels associated with ambient noise sources in the GBMWHA, it is not considered appropriate to assess aircraft noise intrusion by comparing sound pressure levels; the characteristics of aircraft noise and natural sound sources is very different, and are interpreted in very different ways.



The potential for a large number of audible events below 50–55 dB LAmax is therefore considered to potentially represent a significant and widespread impact within the GBMWHA. On this point, we note that the separate assessment of impacts to the GBMWHA presented in Volume 2 of the draft EIS indicates noise levels below 50 and 55 dB LAmax are ‘not significant’. Given the above, the assertion within draft EIS chapter that noise levels below 50 and 55 dB LAmax are ‘not significant’ is not considered to have been sufficiently justified, and the assessment may therefore not adequately reflect the potential impact to the values of tranquillity within the World Heritage Area.

Given the status of the Blue Mountains as a World Heritage Area, and the potential for intrusive impacts, further assessment of this sensitive receiver location is considered to be warranted. In particular, further information should be provided to demonstrate the relative merits of alternative aircraft arrival management procedures which do not involve a concentration of aircraft movements over the GBMWHA. This should include a discussion of the trade-offs between protection of amenity in residential areas and the protection of the GBMWHA. Consideration should also be given to different areas within the GBMWHA noting any areas of increased recreational use or areas where tranquillity and natural soundscapes may be more valuable.

In addition, the technical noise report considers the number of people potentially affected for alternative merge points in general terms. For the two alternative merge points considered, the technical noise reports notes that the flight densities over Blaxland are reduced, and the people affected are aligned to less populated rural residential areas outside the GBMWHA. Track densities and number of aircraft overflights over Blue Mountains’ communities are still predicted to be high, while impacts on some areas within the GBMWHA are increased for the two alternative merge points.

It is therefore unclear why preference has been given to the merge point that affects a greater population, i.e. over Blaxland, in lieu of reducing number of potential affected residences. This is perhaps due to conservation of the world heritage area, though should be confirmed.

Air quality

The air quality impacts relevant to the GBMA have been divided into three elements; regional air quality, climate change and emissions from fuel dumping.

A review of the regional air quality assessment found that the assessment adopted the NSW EPA’s tiered assessment approach which was considered appropriate for this project. All the relevant information regarding how the regional air quality assessment was undertaken, with the exception of detailing how the airport sources were parameterised within the model.

Whilst the change in the daily maximum 1-hour ozone concentration was marginally higher that the 1 ppb defined in the EPA’s tiered approach, the base concentration at the location of the incremental change was approximately 50 ppb (well below the EPA’s impact assessment criterion of 100 ppb). The maximum 1-hour concentrations within the region were not predicted to increase as a result of the Stage 1 Development. Mitigation measures that had a focus on reducing NOx emissions were also recommended for consideration.

The EIS recognises that a challenge identified in world heritage listing (UNESCO, 2015) is the impact of human-enhanced climate change on the GBMA due to the potential for increased temperatures and alteration to the frequency and intensity of fires. A review of the GHG assessment by Katestone Environmental found that despite not specifying the emission factors used to quantify emissions, the greenhouse gas assessment appears to provide reliable estimates of greenhouse gas emissions with the proposed airport representing approximately 0.10% of Australia’s project 2030 transport related GHG emissions inventory.

A review by Katestone Environmental identified that the potential impacts from fuel dumping have not been quantified.



Biodiversity

A review of the biodiversity assessment undertaken for the project found that it generally complied with the EIS guidelines. A partial compliance was identified in relation to a detailed assessment of significance on the Greater Blue Mountains Heritage Area which notes that it will be included in the final draft of the report following a multidisciplinary workshop to assess potential impacts.

Social

The GBMWHA has been included in the social impact assessment as an area that provides a range of recreational pursuits that may be impacted by the proposed airport increasing the number of audible overflights to over 70/day in 2030. A review of this technical report has identified that there is a strong focus on the economic benefits at the regional and national levels however lacks the assessment of economic and social impacts at the local level.

4.8.3.3 Commentary on validity of assumptions

Identification of the sensitive receivers

Sensitive tourism and recreation areas used in the assessment were based on the identification of key attractions and associated viewing locations within the GBMA. The assessment considered the remoteness, accessibility and accommodation options as an indication of the type of tourism and recreational experiences available at each location.

Sensitive areas identified for amenity assessment in the EIS stage 1 were:

Jamison Valley south of Echo Point lookout and the Scenic Cableway at Katoomba and Wentworth Falls lookout;

Grose Valley east of Evans lookout and Govetts Leap lookout;

Wilderness area between Deanes lookout and Crawfords lookout within Wollemi National Park;

Nattai wilderness area;

Kanangra Walls and wilderness area east of Kanagra-Boyd lookout; and

Baal Bone Gap within Gardens of Stone National Park.

Other sensitive receivers not included in the assessment that add to the value of the area include towns located in the lower Blue Mountains e.g. Springwood and Leura, walking tours (Aboriginal Blue Mountains Walkabout tour near Faulcon Bridge), sporting events (six foot track marathon, ultra-trail) canoe/kayak trails along Nepean River, Grose River and further north along the Colo River. Viewing locations that are outside the GBMA, but provide views of the area, for example Burragonang lookout near Oakdale could be impacted by the proposed airport. These areas should have been included in the assessments. It is suggested that further consultation with the Blue Mountains City Council or Tourism Board to understand the full range of users of the area.

World Heritage and National Heritage values

The EIS states that the values identified for the Greater Blue Mountains National Heritage Area and World Heritage Area are the same. A review of the National Heritage criteria for the purposes of this item and the Environment Protection and Biodiversity Conservation Act 1999, found that each world heritage value that the World Heritage Committee has identified for the property triggers the place to meet a National Heritage criterion.

In this regard the EIS has taken the heritage assessment to cover both the national and world heritage values of GBMA, which is considered a suitable approach.



4.8.3.4 Whether the conclusions reached in the studies are valid

The draft EIS concludes:

No direct impacts are expected World Heritage or National Heritage values from the construction or operation of the proposed Western Sydney Airport;

Potential indirect impacts of airport operation would not result in an attribute of the property being lost, degraded or damaged, or notably altered, modified, obscured or diminished.

It is noted that the detailed assessment of significance on the GBMHA has not been completed and will be included in the biodiversity technical report following a multidisciplinary workshop to assess the potential impacts.

4.8.3.5 Review the mitigation and management measures proposed

Mitigation measures referred to in the aircraft noise assessment are generic in nature due to the airspace design not being finalised. Design of airspace arrangements and flight paths for the proposed airport would take into account the potential impact on sensitive areas including GBMA.

The development of a detailed Environmental Management Plan for the project would take into consideration management plans already in place for GBMA; including the Strategic Plan.

4.8.3.6 The level of uncertainty over impacts and the environmental risks

Given the uncertainties concerning the final form of the airspace design, the final form of noise mitigation measures to be implemented is not yet known. Consequently, the mitigation measures that have been referred to in the aircraft noise assessment are generic in nature.


4.8.4.1 Overview of approach to assessment to long term development taken by the EIS

Chapter 38 of the Western Sydney Airport EIS builds on the potential impacts considered for the proposed Stage 1 development (Chapter 26) and takes information from the environmental and social assessments completed for the proposal.

Seven sensitive tourism and recreation areas were identified in relation to the potential impacts from long term development of the airport in relation to noise, air quality and amenity.

Jamison Valley south of Echo Point lookout and the Scenic Cableway at Katoomba and Wentworth Falls lookout;

Grose Valley east of Evans lookout and Govetts Leap lookout;

The wilderness area between Deanes lookout and Crawfords lookout within Wollemi National Park;

The wilderness area between Mt Yengo lookout and Finchley lookout within Wollemi National Park;

Nattai wilderness area;

Kanagra Walls and wilderness area east of Kanangra-Boyd lookout; and

Baal Bone Gap within Gardens of Stone National Park.



The Strategic Plan was used as the basis to form the additional values and existing threats on the GBMA national heritage listing and the outstanding universal value criterion used as to identify the values of the GBMWHA world heritage listing which is considered valid approach for this project.

Assessment of significance for the potential impact on the world heritage values of the GBMWHA was based on the requirements of the EPBC Act Significant Impact Guidelines 1.1. As noted in above in section 3.1.1, this assessment will be finalised following a multidisciplinary workshop.

Mitigation and management of potential noise impacts will be achieved through planning and implementation of flight paths, airspace design and airport operating procedures to support long term airport operations. The uncertainty of the final airspace design means that mitigation and management measures are generic and not accurately reflect the true noise impacts on the area.

4.8.4.2 Commentary on ‘gaps’ relative to a comprehensive/conventional assessment

Any decommissioning impacts have not been discussed assessed however given that the likelihood of the airport being decommissioned is low this project phase is not considered relevant.

Residual impacts have not identified in the EIS and therefore the effectiveness of the proposed management measures will be difficult to monitor.

4.8.4.3 Key impacts and opportunities

The key impacts on the GBMWHA considered during the review relate to the potential indirect impacts from noise and air quality.

The social impact assessment identifies an opportunity for increased tourism to the GBMWHA due to the closer proximity to an airport and the associated transport network. This opportunity has been assigned a high significance rating.

4.9 Biodiversity The adequacy of the above documents was reviewed against the Western Sydney Airport EIS guidelines (the EIS guidelines), biodiversity survey and assessment guidelines and background data, where appropriate. The review criteria comprised:

evaluate if the biodiversity study meets the requirements of the EIS guidelines and other relevant guidelines and methods;

evaluate the validity of the data relied upon to inform the Biodiversity Assessment (draft EIS Appendix K1);

evaluate the validity of the underlying assumptions of the Biodiversity Assessment (draft EIS Appendix K1);

evaluate the validity of the conclusions reached in the Biodiversity Assessment (draft EIS Appendix K1);

review the mitigation and management measures proposed and advise of the adequacy in mitigating impacts; and

evaluate the level of uncertainty of biodiversity impacts and provide advice on the resulting environmental risks.

A summary of the key impacts and opportunities associated with the project has also been provided.



4.9.1 Stage 1 development review findings

The reports were found to be generally compliant with the EIS guidelines. However, a number of partial and non-compliances were identified. The assumptions and conclusions of the assessment were considered valid, with the exception of three criteria which were deemed ‘partially compliant’. The proposed mitigation and management measures were deemed suitable for this stage of the project, with further information required prior to construction with respect to biodiversity and environmental management.

Data gaps were identified with respect to land access restrictions, threatened species locations, the assessment of threatened species, and a large deficit in the proposed offsets. The Biodiversity Assessment (draft EIS Appendix K1) does not clearly define the extent of land access restrictions. A key risk associated with insufficient access (if this is the case) is that biodiversity values and offsetting requirements may have been underestimated.

Assessments of significance were not completed for the Green and Golden Bell Frog, Australasian Bittern, Australian Painted Snipe and a number of migratory species listed under the EPBC Act. Key risks associated with the omission of these assessments are that the level of impact and the offsets required may have been underestimated. The large credit deficit, particularly for Cumberland Plain Woodland in the Sydney Basin Bioregion, listed as a critically endangered ecological community under the Threatened Species Conservation Act 1995 (TSC Act) and Environment Protection and Biodiversity Conservation Act 1999 is a key risk as it is not currently known if the quantum of offsets required is available.

4.9.2 Long-term development review findings

The Biodiversity Assessment (draft EIS Appendix K1) provides a general assessment of adverse the long-term development impacts of the project. However, it does not consider the potential impact of successful implementation of biodiversity management measures from the Stage 1 development, which may result in increased biodiversity values and therefore underestimate the longer-term development impacts. In addition, the Offsets Strategy (draft EIS Appendix K2) does not state how offsets will be identified and secured for the long-term development.


Key impacts of the project comprise:

the loss of 90 ha of Cumberland Plain Shale Woodlands and Shale Gravel Transition Forest critically endangered ecological community; and

the loss of 120 ha of habitat critical to the survival of the Grey-headed Flying-fox, a vulnerable species.

Key opportunities of the project comprise:

location of the airport site on predominantly cleared land;

identification of potentially suitable offset sites on private property that may have otherwise degraded, and been subject to key threatening processes; and

in addition to the offsets, the creation of an on-site environmental conservation zone, containing native vegetation representative of the vegetation types to be cleared.



5. Conclusions WSP | Parsons Brinckerhoff were engaged by WSROC and MACROC to project manage the peer review of the Western Sydney Airport draft EIS.

In this capacity WSP | Parsons Brinckerhoff ran a competitive tendering process to engage specialists in key areas of interest to the councils. WSP | Parsons Brinckerhoff reported to WSROC under the direction of a Steering Committee (of officers of the participating councils) to confirm which specialists should be engaged, the Steering Committee provided direction throughout the review process and reviewed draft inputs.

5.1 Key findings The peer review of the draft EIS outlined five key findings as discussed below. A summary of each specialist reviews is provided in Chapter 4 whilst the detailed specialist peer reviews have been included as Appendix A - I and of this report.

General adequacy

The draft EIS was prepared over a period of approximately 8 months from engagement of draft EIS consultants to provision of an initial draft for Commonwealth Department of Environment review. By way of contrast the previous EIS for the project prepared in the late 1990s was undertaken over well over two years. From our review it is apparent that this has resulted in a number of omissions and limitations, which are discussed through Chapter 3 – Review of the overall draft EIS and Chapter 4 – Review of technical report of this report.

Airport Layout

The draft EIS nominates a preferred airport layout for both the Stage 1 and long term developments, noting that the layouts are indicative only and would be confirmed once an Airport Lease Company (ALC) has been appointed. Alternative layouts are presented for both the Stage 1 and the long term development however no consideration of alternative runway orientations has been undertaken. This contrasts with the EIS undertaken in the late 1990s which examines multiple layouts and runway alignments, and gives little visibility of whether the chosen layout, and in particular the runway alignments, achieve the best environmental outcome. Given the time that has lapsed since the previous EIS it would have been expected to see a thorough current option-evaluation process to explore alternatives.

Airspace architecture (flight paths)

Chapter 7 of the draft EIS describes the ‘Airspace Architecture and Operation’ of the proposed airport which includes the flight paths for the Stage 1 Scenario (2030), prepared by Air Services Australia on behalf of the Department of Infrastructure. Only one set of flight paths are provided in the draft EIS, featuring a ‘merge point’ (a point at which all incoming flights converge) over Blaxland. The concept of merge points is relatively new, and is considered good practice as it allows for incoming flights to minimise thrust and so reduce noise.

The brief of Air Services Australia as outlined in the draft EIS was to develop a set of flight paths that avoids impacts on existing operations at Kingsford Smith at 2030 (although it was acknowledged that this would be impossible in the long term) and to ensure safety of operations. We have a number of concerns in regard to the flight paths presented in the draft EIS specifically around the uncertainty of those described.



To reduce some of this uncertainty, we recommend the following:

Greater consideration of alternative options is required, with an additional objective of minimising environmental impacts.

A holistic review of flight paths taking account of all airports should be undertaken. As a minimum an option that allows for flight paths at Kingsford Smith to be modified should be considered.

In recognition that a future ALC may modify the flight paths, sensitivity testing should have been presented to demonstrate the changes of noise impacts that would result if flight paths are modified.

The case for a merge point should be further explored, and consideration of alternative merge points should be examined.

Draft EIS places no explicit limits on key impacts

In a number of areas the draft EIS does not provide assurances that acceptable environmental thresholds will not be breached, and does not set hard limits on environmental impacts. In the case of aircraft noise this is a reflection of the nature in which aircraft noise is managed in Australia. However the same is also largely true of other aspects of the draft EIS – the mitigation measures are generally not prescriptive, and there is little in the way of hard limits on impacts. This is largely a reflection of the fact that the ALC has not yet been appointed, and that the Department of Infrastructure is seeking flexibility over management and mitigation. However this creates uncertainty over the likely future impacts.

Uncertainties over the way the approvals process will operate

The project is subject to assessment under the EPBC Act, and that the Minister for the Environment’s consent (and conditions) are a prerequisite of any subsequent approval under the Airports Act. The draft EIS notes that the future development and expansion of the airport will be subject to further assessment and approval under the Airports Act, and that the preparation of a masterplan will be required within five years of the commencement of the project. This would superseded the current Airport Plan, which is described in the draft EIS as a transitional document, in effect it is implied that once the airport is leased, all future approvals would be under the Airports Act.

What is less clear is:

What the potential triggers would be for the need for further referrals and potentially approvals under the EPBC Act.

What further assessment and approval would be required (beyond the current EIS and associated Airport Plan approval) once an ALC is appointed and more is known about the actual airport layout and operations.

What limitations any EPBC Act approval will place on the airport.

What level of community engagement will be provided in the process going forward.



6. References Commonwealth of Australia (2015a) draft Environmental Impact Statement. Australian Government, Department of Infrastructure and Regional Development.

Commonwealth of Australia (2015b) DRAFT Airport Plan, Western Sydney Airport. Australian Government, Department of Infrastructure and Regional Development. October 2015

DECC (2009) Greater Blue Mountains World Heritage Area Strategic Plan. Department of Environment and Climate Change (NSW)

Department of Environment (2013) Matters of National Environmental Significance Significant impact guidelines 1.1.

enHealth (2001) Health Impact Assessment Guidelines. enHealth Council

enHealth (2004) The Health Effects of Environmental Noise other than Hearing Loss. enHealth Council May 2004.

Mestre, V (2008) Synthesis 9 - Effects of Aircraft Noise: Research on Selected Topics. Washington, D.C: Airport Cooperative Research Program by the US Transportation Research Board

Standards Australia (2015) Acoustics-Aircraft noise intrusion-Building siting and construction, AS 2021-2015, Standards Australia, Sydney

UNSW and NSWHealth, 2007 Health Impact Assessment: A practical guide. Centre for Health Equity Training, Research and Evaluation (CHETRE). August 2007

Appendix AAircraft overflight noise (Marshall Day Acoustics)

WESTERN SYDNEY SECOND AIRPORT DRAFT EIS OVERFLIGHT NOISE PEER REVIEW

Rp 001 R01 2015417ML | 27 November 2015

http://www.marshallday.com

6 Gipps Street

Collingwood VIC 3066

Australia

T: +613 9416 1855

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www.marshallday.com

Project: WESTERN SYDNEY SECOND AIRPORT DRAFT EIS PEER REVIEW

Prepared for: WSP / Parsons Brinckerhoff Australia Pty Ltd Level 27, Ernst & Young Centre 680 George Street Sydney NSW 2000 AUSTRALIA

Attention: Mr Paul Greenhalgh

Report No.: Rp 001 R01 2015417ML

Disclaimer

Reports produced by Marshall Day Acoustics Pty Ltd are prepared based on on a specific scope, conditions and limitations, as agreed between Marshall Day Acoustics and the Client. Information and/or report(s) prepared by Marshall Day Acoustics may not be suitable for uses other than the original intended objective. No parties other than the Client should use any information and/or report(s) without first conferring with Marshall Day Acoustics.

We stress that the advice given herein is for acoustic purposes only, and that the relevant authorities and experts should be consulted with regard to compliance with regulations or requirements governing areas other than acoustics.

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The concepts and information contained in this document are the property of Marshall Day Acoustics Pty Ltd. Use or copying of this document in whole or in part without the written permission of Marshall Day Acoustics constitutes an infringement of copyright. Information shall not be assigned to a third party without prior consent.

Document Control

Status: Rev: Comments Date: Author: Reviewer:

Draft - For WSP / PB review 10/11/2015 J. Adcock &

A. Morabito

J. Adcock &

A. Morabito

Final - For external distribution 20/11/2015 J. Adcock &

A. Morabito

J. Adcock

A. Morabito &

S. Peakall

Final 01 Amended council references

27/11/2015 J. Adcock -

EXECUTIVE SUMMARY

Introduction

Marshall Day Acoustics Pty Ltd (MDA) has carried out a peer review of the aircraft overflight noise assessment presented in the draft Environmental Impact Statement (draft EIS) for the proposed Western Sydney Airport (the proposed airport).

The peer review specifically relates to the draft EIS noise assessment of airborne aircraft operations associated with the proposed airport, and the associated ground movements for takeoff and landing. A separate report by WSP Parsons Brinckerhoff documents a peer review of noise impacts associated with construction and aircraft ground operations (including taxiing and engine run-up testing) for the proposed airport.

The objective of this peer review was to assess the reliability and technical accuracy of the aircraft overflight noise assessment.

The peer review considers the following proposed stages of development:

Stage 1 development comprising a single 3,700 m runway with 63,000 aircraft movements per year which are projected to occur by 2030;

Longer term development of the single runway to facilitate 164,000 aircraft movements per year which are projected to occur by 2050; and

Longer term development with an additional parallel runway to enable additional capacity increases to 370,000 aircraft movements per year which are projected to occur by 2063.

Approach

The peer review has been primarily based on information presented in the noise chapters for the Stage 1 proposal and long term developments, in conjunction with the technical noise report presented in Appendix E1 of the draft EIS.

Consideration has also been given to other related sections of the draft EIS to review the broader assessment of noise impacts. The review of these additional sections has been concerned solely with matters related to the aircraft noise assessment. Reference should be made to the separate peer reviews commissioned by WSP Parsons Brinckerhoff for the review of specialist matters directly concerning aviation, fauna, health, planning and social issues.

This peer review addresses the following key elements of the aircraft noise assessment:








In reviewing these aspects of the draft EIS, consideration has been given to the document Guidelines for the content of a draft Environmental Impact Statement – Western Sydney Airport (Reference: EPBC 2014/7391 and subsequently referred to as the EIS guidelines).

Tasks not conducted as part of this peer review include:

Consultations with any members of the project team involved in preparing the draft EIS;

Site studies;

Review of noise modelling files; or

Noise modelling for the purpose of validating any of the results presented in the draft EIS

Review Findings – Stage 1 Development

The noise modelling is considered to generally provide a reasonable representation of the extent of noise impacts for the specific flight tracks and operating scenarios that have been proposed. Specifically, predicted noise levels have been determined for a range of operating scenarios. Aircraft noise information has also been produced in a range of formats that are generally consistent with current federal government guidelines for identifying areas potentially affected by aircraft noise.

All noise predictions have been determined using the latest version of the US Federal Aviation Authority’s Integrated Noise Model (INM). This software is used widely in Australia and internationally for aircraft noise predictions and is the appropriate choice for this application. However, the use of this software to calculate short term noise levels, which is the main form of noise data used in the draft EIS to identify the extent of affected areas, requires careful consideration. Specifically, the INM supporting documentation notes:


Accordingly, while the use of the INM is reasonable, information has not been provided as part the draft EIS to verify the reliability of the short term noise level data (presented as maximum noise levels and Number Above ratings). This is particularly important for this proposed airport, because of the increased uncertainty associated with the predictions at the lower noise thresholds used in the draft EIS for the assessment of night-time operations and impacts in quiet areas such as the Greater Blue Mountains World Heritage Area.

Notwithstanding the general suitability of the noise modelling data, there are however a number of limitations to the assessment. These relate to the uncertainty surrounding the airspace management design, and the limited assessment of the noise modelling outcomes. These matters are summarised as follows.


The total aircraft movement numbers for the Stage 1 development are relatively low when compared to other international airports in Australia. The low movement numbers cast doubt over the suitability of the 5 year time horizon as the primary assessment scenario for the purpose of obtaining approval for a major international airport. In this context, it is unclear how the incremental and periodic approvals that would need to occur as part of the ongoing expansion of the airport provide a sufficient basis for considering the initial 5 years of operation as the primary period for the assessment of noise impacts.

These comments are provided primarily in relation to the plausibility of the movement numbers represented in the noise modelling, based on comparisons with movement numbers documented in the noise modelling for other Australian international airports and similar time horizons. Aircraft traffic forecasts are however outside of our area of expertise and therefore the suitability of the specific movement numbers provided for the noise assessment are considered in further detail in a separate aviation peer review commissioned by WSP Parsons Brinckerhoff.


The draft EIS states that the airspace management strategy used as the basis for noise modelling is a proof-of concept design, and that further work is required to determine the actual flight paths which would be flown in practice. Information about the extent of potential flight path changes is limited. The uncertainty surrounding the final airspace management design that would be implemented represents a significant source of uncertainty in the noise assessment. The potential significance of this source of uncertainty has not been quantified and, with exception of alternative merge points for Stage 1, there has not been any sensitivity analysis carried out to assess the implications of potential flight path changes.


The draft EIS includes exposed population statistics which provide a useful indication of the number of people who may be affected by aircraft noise to varying degrees. However, in isolation, this data does not provide an indication of the scale or significance of potential community reaction to aircraft noise levels as a result of annoyance. The Health Risk Assessment in the draft EIS provides the most discussion of community annoyance, including references to research concerning the relationship between noise exposure and community annoyance. However, the Health Risk Assessment ultimately states that no quantitative assessment of annoyance was conducted as part of the study.

Dose-response relationships of the types referenced in the Health Risk Assessment can be used with noise levels and population data to provide a quantitative measure of the potential reaction. The use of these established relationships to represent the reaction of a separate community exposed to aircraft noise must be used with caution. In particular, due consideration must be given to the increased reaction that may be expected from a newly exposed community. However, this type of analysis provides an objective basis for comparing the impacts of alternative operating strategies and, more broadly, establishing the risk of community noise impacts relative to other established international airports in Australia.

While the assessment of the risk of community annoyance is complex, the scale of the proposed airport, and the number of people potentially affected, are sufficiently large to warrant further evaluation of the subject. The introduction of a new 24-hour international airport at a greenfield development site introduces a risk of widespread and prolonged community annoyance. A quantitative analysis of this potential risk would be prudent to inform the environmental impact assessment process and the extent to which operational noise mitigation should be prioritised relative to other non-safety related airspace management considerations. Updated social surveys of the type originally carried out as part of the development of the Australian Noise Exposure metric used in Australia also warrant some consideration, given the significant nature of the proposed development and the availability of detailed aircraft noise information for other existing Australian airports.

Land use impacts

The draft EIS includes calculated Australian Noise Exposure Concept (ANEC) contours for the Stage 1 operating scenarios. ANECs are often presented as an indication of the extent of a potential future Australian Noise Exposure Forecast (ANEF) contour which would be used to guide land use planning for noise-sensitive developments in the vicinity of airports.

However, as acknowledged in the draft EIS, the ANEC contours presented for the Stage 1 proposal provide limited guidance for the purpose of land use planning. The reason for this is that the ANEF is normally derived from ANECs calculated for long term operations or ultimate capacity scenarios, rather than short term ANECs related to an initial phase of operation. Evaluation of land use planning impacts must therefore be primarily based on the ANEC contours presented for the long term development of the airport, rather than initial Stage 1 development contours.

Greater Blue Mountains World Heritage Area

The draft EIS presents information to evaluate the potential impacts of aircraft operations on the acoustic amenity of the Greater Blue Mountains World Heritage Area (GBMWHA). The assessment indicates the potential for a large number of audible aircraft events within the GBMWHA.

The preservation of quiet areas and tranquil landscapes has been a topical subject of research and policy consideration in Europe and the US. For example, the US Transportation Research Board publication on the effects of aircraft noise (Mestre, 2008) includes a chapter which discusses research and US legislation (National Parks Overflight Act of 1987) concerning the effects of aviation noise on parks, open space and wilderness areas. These publications do not provide definitive guidance on assessment techniques, but highlight the complexity and importance of assessing aircraft overflight noise in sensitive wilderness areas.

While the noise levels in the draft EIS are predicted to be relatively low (below 50 – 55 dB LAmax), aircraft over flights would be expected to be audible and represent a significant and widespread impact for a World Heritage Area where natural soundscapes are likely to be a valued feature of the areas amenity. The complexities and sensitivities of this area warrant further consideration in the draft EIS. Specifically, the assertion within the draft EIS chapter concerning the GBMWHA that noise levels below 50 and 55 dB LAmax are ‘not significant’ is not considered to have been sufficiently justified, and the assessment may therefore not adequately reflect the potential impact to the values of tranquillity within the World Heritage Area.


The draft EIS noise modelling is based on an indicative proof-of concept air traffic management design which does not present a comprehensive airspace and final air route design. Given the uncertainties concerning the final form of the airspace design, the final form of noise mitigation measures to be implemented is not yet known. Accordingly, the mitigation measures that have been referred to in the aircraft noise assessment are generic in nature.

This is a particularly important point for an airport development as, unlike other forms of infrastructure development, the policies used to manage aircraft overflight noise do not generally stipulate noise limits that airport operations must adhere to at surrounding noise-sensitive locations.

Accordingly, without a defined airspace design, a defined noise mitigation strategy or defined noise criteria to adhere to in practice, the residual impacts and the location of these impacts is subject to considerable uncertainty. Further, without defined noise criteria, it is unclear how noise considerations would be prioritised among other non-safety related airspace management and operational considerations associated with the proposed airport site. These uncertainties may therefore warrant consideration of performance criteria as part of the approval process for the proposed airport.

In addition to the generic operational measures for the mitigation of noise, the draft EIS also refers to mitigation related to dwelling acquisition or dwelling insulation upgrades. There is however no detail provided in terms of the circumstances in which these measures would be implemented, other than a general reference to the guidance of AS 2021. It is unclear if this is intended to infer that such measures would only be considered within certain Australian Noise Exposure areas, or if such measures would be considered at all locations where internal levels may be expected to exceed AS 2021 internal design criteria as a result of the proposed aircraft operations.

Review Findings – Long Term Development

A number of the considerations identified from the peer review of the Stage 1 development are directly relevant to the assessment of the long term development scenarios. For example, matters related to the noise prediction methodology are identical for the Stage 1 and long term development scenarios.

In terms of assumptions about operational capacity, the movement numbers for the 2050 single runway scenario and 2063 dual runway scenario are comparable to the range of movement numbers documented for other similar Australian international airports. On this basis, the values appear to be plausible for noise assessment purposes. Aircraft traffic forecasts are however outside of our area of expertise and therefore the suitability of the specific movement numbers provided for the noise assessment are considered in further detail in separate aviation peer review commissioned by WSP Parsons Brinckerhoff.

The following limitations are however noted for the long term assessment scenarios.

Land Use Impacts

The draft EIS presents ANECs for a range of operating scenarios in 2050 and 2063 as part of the discussion of potential land use impacts which may result from a future ANEF for the proposed airport.

However, the latest Australian Standard (AS 2021) which defines how Australian Noise Exposure data should be used to inform land use planning includes guidance on how ANECs for multiple operating scenarios may be combined to define an overall area where planning controls should apply. The draft EIS does not refer to this guidance and it is therefore unclear how the various ANECs should be interpreted when assessing land use impacts.

Further, while the draft EIS provides population counts for the various ANEC bands, no assessment is provided of the extent to which land use controls may change as a result of a future ANEF prepared as part of the detailed airspace design for the project. Specifically, the draft EIS does not quantify the potential extent of changes to land use controls relative to the measures which have been in place since the original EIS was undertaken in 1985.

Furthermore, the discussion of land use planning impacts in the draft EIS notes that the National Airports Safeguarding Framework would ‘be instrumental in managing potential future operational noise impacts for future land use planning and development around the airport’. The Framework could potentially translate to the creation of land use planning controls which extend over significantly greater areas than either the current land use planning controls (based on the 1985 EIS) or the 2063 ANEC contours provided in the draft EIS. This has however not been discussed or assessed in the draft EIS.

Cumulative Impacts

The draft EIS notes that the parallel runway scenario (2063) would introduce a number of issues which would need to be addressed in the final airspace design. In particular, the chapter concerning airspace architecture notes the following issues that would need to be addressed:

Changes to Sydney Airport flight paths ;

Changes to flight paths serving Bankstown Airport; and

Resolution of a potential constraint associated with the restricted airspace over Defence Establishment Orchard Hills.

The EIS guidelines establish a requirement to ‘identify and address cumulative impacts, where potential project impacts are in addition to existing impacts of other activities’.

The above issues concerning the airspace architecture are considered to represent potential cumulative impacts which have not been quantified in the draft EIS. Further information concerning this issue is therefore considered necessary to address the requirements of the EIS guidelines.

Key Impacts and Opportunities

The findings of the peer review indicate that noise level information of the form required by the EIS guidelines has generally been provided in the draft EIS. However, the peer review has also identified a number of limitations concerning the content of the draft EIS, and therefore further information and assessments are considered necessary to address the general and noise-specific requirements of the EIS guidelines.

Based on the review of the draft EIS, the key noise impacts associated with the proposed airport are:

Community annoyance, and related impacts such as speech interference and changes to the way individuals use outdoor spaces;

Sleep disturbance associated with night-time operations, and related impacts such as the potential need for some residents to sleep with windows closed to achieve a suitable internal amenity; and

Degradation of the acoustic amenity of the World Heritage Area within the Greater Blue Mountains area

In terms of land use impacts, the existing planning instruments that have been used to control development around the proposed airport site would generally be expected to limit the extent of the potential impacts. However, the draft EIS reference to the National Airports Safeguarding Framework as an instrumental tool for guiding future land planning around the proposed airport site introduces the potential for significantly enlarged development controls. This could translate to land use impacts also being a key impact associated with the proposed development.

Other noise related impacts cornering matters such as health, property values and social impacts are addressed in separate peer reviews commissioned by WSP Parsons Brinckerhoff.

Aircraft noise impacts are an unavoidable consequence of aircraft operations in urban environments. The creation of a new international airport therefore requires a balance to be achieved between the protection of amenity for neighbouring sensitive land uses and the development of infrastructure to respond to the growing demands of a major city.



Provide clarity to affected communities and stakeholders about the nature of the noise impacts;

Provide clarity to regulators about the form of noise controls which will be needed in the project approval to ensure that noise is appropriately managed; and

Reduce the potential for unforeseen impacts and the associated risk of reactionary noise management procedures which could subsequently jeopardise the operational flexibility of the proposed airport.

TABLE OF CONTENTS

1.0 INTRODUCTION ....................................................................................................................................... 1

2.0 REVIEW FINDINGS – STAGE 1 DEVELOPMENT ...................................................................................... 3

2.1 EPBC Act and EIS Guidelines ................................................................................................................... 3

2.2 Noise Prediction Methodology .............................................................................................................. 4

2.2.1 Runway .................................................................................................................................................... 4

2.2.2 Terrain Data ............................................................................................................................................. 4

2.2.3 Flight Paths .............................................................................................................................................. 5

2.2.4 Flight Profiles ........................................................................................................................................... 6

2.2.5 Movement Numbers............................................................................................................................... 7

2.2.6 Aircraft Fleet Mix ..................................................................................................................................... 8

2.2.7 Calculation Procedure ............................................................................................................................. 8

2.2.8 Meteorological Conditions ..................................................................................................................... 9

2.2.9 Uncertainties ......................................................................................................................................... 10

2.3 Noise Prediction Data ........................................................................................................................... 10

2.3.1 Airport operating modes ...................................................................................................................... 10

2.3.2 Calculation Metrics and Scenarios ....................................................................................................... 11

2.4 Impact Assessment Methodology ....................................................................................................... 12

2.4.1 Methodology Overview ........................................................................................................................ 12

2.4.2 Sensitive Receivers and Noise Exposure Data ..................................................................................... 14

2.4.3 Community Annoyance Assessment ................................................................................................... 15

2.4.4 Sleep Disturbance Assessment ............................................................................................................ 16

2.4.5 Land Use Impacts .................................................................................................................................. 17

2.4.6 Dwelling Insulation ................................................................................................................................ 18

2.4.7 General Recreation Areas ..................................................................................................................... 18

2.4.8 Greater Blue Mountains World Heritage Area ................................................................................... 18

2.5 Alternatives ............................................................................................................................................ 19

2.6 Proposed Mitigation Measures ............................................................................................................ 20

3.0 REVIEW FINDINGS – LONG TERM DEVELOPMENT ............................................................................. 22

3.1 2050 – Additional capacity single runway ........................................................................................... 22

3.1.1 Flight paths ............................................................................................................................................ 22

3.1.2 Movement numbers ............................................................................................................................. 22

3.1.3 Land use impacts ................................................................................................................................... 23

3.2 2063 – Parallel runway ......................................................................................................................... 23

3.2.1 Runway position .................................................................................................................................... 23

3.2.2 Departure tracks .................................................................................................................................... 23

3.2.3 Cumulative impacts ............................................................................................................................... 23

3.2.4 Operating modes ................................................................................................................................... 24

3.2.5 Land use impacts and dwelling insulation ........................................................................................... 24

4.0 SUMMARY ............................................................................................................................................. 26

5.0 MDA PEER REVIEW PERSONNEL .......................................................................................................... 29

APPENDIX A GLOSSARY OF TERMINOLOGY

APPENDIX B REFERENCES

Rp 001 R01 2015417ML Western Sydney Airport Overflight Noise - Peer Review 1

1.0 INTRODUCTION

This document presents the findings of Marshall Day Acoustics’ peer review of the aircraft overflight noise assessment presented in the draft Environmental Impact Statement (draft EIS) for the proposed Western Sydney Airport (the proposed airport), released on 19 October 2015.

The peer review specifically relates to the draft EIS noise assessment of airborne aircraft operations associated with the proposed airport, and the associated ground movements for takeoff and landing (subsequently referred to as the aircraft noise assessment within this document). A separate report by WSP Parsons Brinckerhoff documents a peer review of noise impacts associated with construction and aircraft ground operations (including taxiing and engine run-up testing) for the proposed airport.

The peer review considers the following proposed stages of development:

Stage 1: development of a single 3,700 m runway at the northern end of the candidate site referred to as Badgerys Creek, with 63,000 aircraft movements per year projected to occur by 2030;

Longer term development of single runway capacity: incremental development of aviation infrastructure and support services to facilitate 164,000 aircraft movements per year which are projected to occur by 2050; and

Longer term development with an additional parallel runway to the south: an additional runway is proposed for long term operations, enabling additional capacity increases to 370,000 aircraft movements per year which are projected to occur by 2063.

The peer review was commissioned by WSP Parsons Brinckerhoff on behalf of the following organisations:

Western Sydney Regional Organisation of Councils (WSROC); and

Macarthur Regional Organisation of Councils (MACROC).

The above organisations are collectively referred to as the Councils within this document.

The objective of the peer review was to assess the reliability and technical accuracy of the aircraft noise assessment in the draft EIS, in turn assisting the Councils to reach an informed view on potential aircraft noise impacts within their respective shires.

The scope of the peer review was defined by the following requested tasks:

Evaluate whether the noise and vibration study meet the requirements of the EIS Guidelines and relevant other guidelines and methodologies with respect to aircraft noise;

Evaluate whether the underlying assumptions used to inform the assessment (including any construction or operational assumptions, and modelling assumptions where appropriate) are plausible;

Evaluate whether the conclusions reached in the studies are valid i.e. an independent evaluation of whether the predicted impacts are in accordance with published standards and guidelines, and whether the conclusions of the assessment are a realistic reflection of the actual impacts;

Review the mitigation and management measures proposed and advise on their adequacy in mitigating impacts;

Evaluate the level of uncertainty over impacts and the environmental risks that will arise as a result; and

Provide a summary of the key impacts and opportunities associated with the project in relation to aircraft noise as part of the noise and vibration study.

The primary documents that have been reviewed in detail are set out in Table 1.


Table 1: Primary draft EIS sections considered in peer reviewing the aircraft noise assessment

Draft EIS Section Title

Volume 2 – Stage 1 Development Chapter 10 – Noise (aircraft)

referred to herein as the Stage 1 noise chapter

Volume 3 – Long Term Development Chapter 31 – Noise (aircraft)

referred to herein as the long term development noise chapter

Volume 4 – EIS Technical Reports Appendix E1 – Aircraft overflight noise

referred to herein as the technical noise report

The peer review has also considered additional sections of the draft EIS for contextual information, and to provide informative commentary of the broader assessment of noise impacts which has been presented in other related sections of the draft EIS. The review of these additional sections has been concerned solely with matters related to the aircraft noise assessment. In particular, the review of specialist sections such as airspace architecture, human health and social impacts was limited to technical matters concerning noise modelling scenarios, noise level information and noise mitigation measures. Reference should be made to the separate peer reviews commissioned by WSP Parsons Brinckerhoff for the review of specialist matters directly concerning aviation, fauna, health, planning and social issues. All instances in which the commentary within this peer review relates to a section of the draft EIS other than the primary reference documents listed in Table 1 are identified by a reference to the section of the draft EIS in question.

This peer review has been conducted solely on the basis of the published documentation in the draft EIS. Tasks not conducted as part of this peer review include:

Consultations with any members of the project team involved in preparing the draft EIS;

Review of noise modelling files; or

Noise modelling for the purpose of validating any of the results presented in the draft EIS.

A glossary of terminology used in this report is provided in Appendix A.


2.0 REVIEW FINDINGS – STAGE 1 DEVELOPMENT

This section presents a review of the aircraft noise assessment for the Stage 1 Development, having regard to:








2.1 EPBC Act and EIS Guidelines

In conducting this peer review, reference has been made to the document Guidelines for the content of a draft Environmental Impact Statement – Western Sydney Airport (Reference: EPBC 2014/7391 and subsequently referred to as the EIS guidelines).

The EIS guidelines establish general content requirements relating to matters including:

Detailed descriptions of the proposed actions;

Description of baseline conditions;

Description of mitigation measures; and

Description of residual impacts following the implementation of mitigation measures.

In addition, the EIS guidelines note the following requirements directly related to noise:

Impacts to the environment (as defined in section 528) should include but not be limited to the following:

…

aircraft noise and vibration impacts on everyday activities and on sensitive environmental receptors (all sensitive receptors within the community and natural environment). Discussion and quantification/modelling of aircraft noise impacts should include consideration of all potential flight paths, height of flights, noise exposure patterns, noise contours, the range of frequencies of the noise, cumulative exposure, peak noise, frequency of overflights and temporal variability of this (including long term trends), varying aircraft types, varying aircraft operating procedures, and variations in noise patterns due to seasonal and meteorological factors

The subsequent sections of this document review the draft EIS against the general and noise-specific requirements of the EIS guidelines.

The findings of the peer review indicate that information of the form required by the EIS guidelines has generally been provided in the draft EIS. However, the peer review has also identified a number of limitations concerning the content of the draft EIS, and therefore further information and assessments are considered necessary to address the general and noise-specific requirements of the EIS guidelines.


In particular, these matters relate to:

The uncertainty surrounding the airspace management design for the proposed airport, and the corresponding uncertainty this introduces into the noise modelling;

As a result of the further work required to develop the airspace management design, the proposed mitigation measures have not been developed in detail. As a result, the residual impacts of the proposed airport are not defined; and

The absence of assessments to evaluate the significance of the predicted noise impacts in terms of community annoyance and land use impacts.

Further discussion of each of these points is provided in the following sections.

2.2 Noise Prediction Methodology

This section provides a review of the input data, assumptions, calculation procedures and calculation settings associated with the noise predictions.

2.2.1 Runway

The technical noise report documents a runway position and configuration which appears to be consistent with the description provided in Volume 1 Chapter 1 Introduction. However, the following specific observations are noted:

The project description in the Stage 1 noise chapter, the technical noise report and Volume 1 Chapter 7 Airspace architecture and operation do not define specific location details in terms of an aerodrome reference point, runway end coordinates or elevation details.

The runway orientation adopted in the noise assessment is consistent with the general description of the Stage 1 proposal and assumes a single southwest / northeast runway designated as runway 23 and 05 respectively. However, the precise orientation of the runway does not appear to have been defined in the project description in the technical noise report or the discussion of airspace architecture presented in Volume 1 Chapter 7, nor is it clear whether the proposed orientation of the runway has been finalised. It is noted that the discussion in Volume 1 Chapter 7 documents the review work conducted by the Australian Bureau of Meteorology to verify the proposed runways 05 and 23. However, the convention of defining runway directions in 10 degree increments means that runways 05 and 23 may relate to direction ranges of 45 to 54 degrees and 225 to 234 degrees respectively. If the runway orientation has not been finalised, this could translate to a significant source of uncertainty in the final location of noise contours.

2.2.2 Terrain Data

The technical noise report specifies the use of terrain data in 10 m height intervals.

The origin of this data has not been specified, however the stated resolution of the terrain data that has been used is considered appropriate for noise modelling purposes.


2.2.3 Flight Paths

The technical noise report specifies that the noise modelling has been prepared on the basis of indicative flight paths prepared by Airservices Australia, noting the following:

Airservices Australia has assessed the airspace implications and air traffic management approaches for Sydney basin airspace arising from the potential introduction of operations at the proposed Western Sydney Airport. The principal objective was to establish whether safe and efficient operations could be introduced at the airport by developing indicative proof-of concept air traffic management designs. Importantly, this work does not present a comprehensive airspace and air route design, nor does it consider all of the essential components that would be necessary to implement an air traffic management plan for the Sydney basin.

Section 7.6 also notes

The conceptual airspace design presented in this draft EIS has not been developed to a level of detail necessary for implementation…

The indicative flight paths therefore do not represent the final flight paths which would be flown if the project proceeds; this is to be expected given the current stage of the proposal. However, the description of airspace architecture in Volume 1 Chapter 7 does not provide any indication of the manner or extent to which the final airspace design may vary from the proof-of concept design, nor is this matter addressed in the technical noise report. This represents a significant source of uncertainty in the predicted noise levels.

The following additional items are noted:

The flight tracks depicted in Figure A1 of Appendix A of the technical noise report indicate that all departures from runway 05 turn left approximately 3 km from the runway end and head due north for 25 km before branching out in a number of directions. This route still passes over populated areas but avoids direct overflight of the relatively densely populated areas to the northeast, such as Blacktown, thus potentially offering benefits in relation to noise. However, while the discussion in Section 7.6.1 of Volume 1 Chapter 7 (airspace architecture) outlines the considerations (including noise) that were factored into the indicative arrival procedures, there is no specific mention of the basis for this departure route. Given that subsequent sections of the technical noise report identify movements on runway 05 result in the greatest total population numbers within the forecast noise contours, it would be prudent to establish the role of noise considerations in the development of this departure track, and the potential extent to which this track may vary in the development of a final airspace management plan.

The proposed airspace configuration includes a single nominated merge point system applicable for arrivals on each runway. From the description provided in Volume 1 Chapter 7 (airspace architecture), it is understood this system is not presently in use in Australia, and is noted to have been selected for a range of operational reasons. One of these reasons is noted to be noise benefits, presumably on the basis of the reduced noise of continuous descent arrival procedures. However, the noise assessment subsequently identifies that the merge point introduces a number of noise considerations related to the areas beneath the merge point and beneath the arrival paths from the merge point. Accordingly, further discussion of the reasons and justification for proposing a merge point system, with reference to the noise impacts of alternative arrival management options, would be prudent.


The discussions of airspace architecture in Volume 1 Chapter 7 and in the technical noise report note that the arrival flight paths do not include any dispersion, other than the inclusion of visual approach paths to the merge point which introduce a form of dispersion. The reason is noted to be the tight control available with instrument/satellite assisted arrival procedures. The absence of dispersion has the effect of concentrating noise levels under the flight path, while conversely limiting the spread of noise into other surrounding areas. This is quite an important consideration for the areas located beneath the arrival paths. Further information to support that arrival movements in practice would not significantly deviate from the designated flight paths would be helpful.

2.2.4 Flight Profiles

Arrivals

The technical noise report notes at Section 2.6.1 that the noise modelling assumes that all arrival profiles will be flown using a procedure known as continuous descent approach (CDA).

CDA involves the aircraft approaching the airport at a nominated location (referred to as the merge point), before descending at a constant angle prior to landing. In contrast, standard arrival procedures involve the aircraft stepping down and flying at constant altitude prior to the final descent and landing. As such, the CDA offers potential benefits for reducing ground noise levels as well as allowing aircraft to save significant fuel amounts and hence reduce other emissions, such as carbon dioxide.

It is however noted that around busy airports, or locations where airspace is congested, as is anticipated to be the case with the proposed airport and the existing Sydney Airport and other smaller airports, that CDA can be difficult to achieve for all arrival operations(Airservices Australia, 2012). Airspace management and other factors, including bad weather, could prohibit the use of CDA for all arrival operations. Furthermore, information provided in Volume 1 Chapter 7 Airspace architecture notes the following in Section 7.6:

If the point merge system is adopted for the proposed airport, the location of the merge point would be a key component of this further development.

As the assessment assumes 100 % of arrivals adopt CDA, hence reducing the extent of predicted noise contours, it would be prudent for the assessment consider a percentage of arrival operations that would adopt a standard approach flight profile. Conversely, consideration of a conservative situation whereby standard approach flight profiles are assumed to account for expected variation in airspace management requirements for a new airport, with progressively increased CDA usage when feasible.

Departures

The technical noise report notes at Section 2.9 that the noise modelling assumes standard aircraft departure profiles for all aircraft operations. However, the International Civil Aviation Organization (ICAO) defines noise abatement departure procedures (NADP) which can be used by civilian jet operations to reduce noise levels at varying distances from an airport. Data for NADP movements is contained in the Integrated Noise Model (INM) software and can be used to calculate the potential effectiveness of NADP operations for a given airport.

The technical report notes that final design of airspace management arrangements for the airport, including flight paths and procedures, would need to be optimised for noise management purposes as part of the work that Airservices Australia would undertake before the proposed airport becomes operational.


However, in contrast to arrival procedures, there is no mention of the potential use of NADP in the Stage 1 noise chapter or technical noise report. It is unclear if these types of procedures would be considered as part of the final design of airspace management arrangements, and if so, under what circumstances they would be proposed.

2.2.5 Movement Numbers

A general review of the movement numbers associated with Stage 1 development has been carried out by comparing the values with current and future movements at other Australian international airports. Figure 1 shows the proposed daily movement numbers for the Stage 1 development appear relatively low compared with other Australian international airports. This may be reasonable given the relatively short time period of 5 years between the commencement of operations and the assessment year. However, this directly translates to a relatively low numbers of aircraft events exceeding relevant noise thresholds when compared to the longer term development plans for the site. Given the objective of the proposal is to develop a major international airport, the relatively low movement numbers raises the question of the suitability of the 5 year time horizon as the appropriate primary assessment scenario for the purpose of obtaining approval for the development, irrespective of the incremental and periodic approvals (under the Airports Act) that would need to occur as part of the ongoing expansion of the airport.

Figure 1: Comparison of average daily airport movement numbers with other existing Australian International airports

It is noted that the draft EIS refers to ongoing development of airside infrastructure to facilitate the continued growth of the airport. However, it is unclear whether the initial primary infrastructure is to be developed to accommodate a greater number of movements than is projected to occur in Stage 1. Further, it is unclear whether an approval for Stage 1 would specifically restrict the movements to the forecast values presented in the draft EIS. Given these considerations, further information concerning the implications of greater than expected demand under Stage 1 would assist in understanding whether the movement numbers, and therefore the predicted noise levels, could be higher than the forecasts presented in the draft EIS.


These comments are provided primarily in relation to the plausibility of the movement numbers represented in the noise modelling, based on comparisons with the movement numbers documented in the noise modelling for other Australian international airports and similar time horizons. Aircraft traffic forecasts are however outside of our area of expertise and therefore the suitability of the specific movement numbers adopted for the stage 1 noise assessment are considered in further detail in a separate aviation peer review commissioned by WSP Parsons Brinckerhoff.

2.2.6 Aircraft Fleet Mix

The aircraft noise modelling has been based on a range of different aircraft types to represent the overall mix of aircraft that is expected to operate from the proposed Stage 1 development.

The selected aircraft types that have been included in the modelling are considered appropriate. Further, the noise modelling has opted for a conservative approach by assuming that all future aircraft operations are characterised by the noise emissions of existing aircraft. Given that aircraft are generally expected to produce lower noise emissions in future, this choice is considered to be reasonable and conservative.

Further, the choice for particular aircraft types and single event noise contours is considered conservative. For example, the freight Boeing 747-400 which is being phased out and replaced by the newer Boeing 747-800.

These comments are provided solely on the basis of the mix of INM aircraft assignments that have been adopted to represent the proposed fleet mix. Forecast aircraft fleet mix are outside of our area of expertise and are considered in further detail in the separate aviation peer review commissioned by WSP Parsons Brinckerhoff.

2.2.7 Calculation Procedure

The Integrated Noise Model (INM) version 7.0d developed by the United States Federal Aviation Authority (FAA) has been used to calculate noise levels associated with the proposed airport operations.

The technical noise report acknowledges that INM has been superseded by the Aviation Environmental Design Tool (AEDT) Version 2b, released in May 2015. The technical report then goes on to note that the core procedures for calculating of noise levels are equivalent between the INM and AEDT programs. This is reasonable and it is not expected that the calculation outputs of the two programs would differ significantly. The use of the latest version of INM is therefore considered appropriate. However, its use for the calculation of a range of different noise exposure metrics warrants further consideration.

The INM was primarily designed for the calculation of long term energy-based exposure metrics such as the Australian Noise Exposure (ANE), equivalent noise level (LAeq), and day night noise level (Ldn). In this respect, the user guide for the software notes:

INM is designed to estimate long-term average effects using average annual input conditions. Because INM is not a detailed acoustics model, differences between predicted and measured values can and do sometimes occur because important local acoustical variables are not averaged, or because complicated physical phenomena are not explicitly modelled.

The program also enables the calculation of short term event levels such as the maximum level, and it is widely used for this purpose. However, in relation to the use of INM for short term maximum noise levels, the user guide notes:



This is an important point as the Number Above contours which are used in the draft EIS to demonstrate the potential extent of noise impacts associated with the proposed airport are based on maximum noise levels calculated using the INM. Accordingly, while the use of the INM for calculating the maximum (LAmax) noise levels is considered reasonable, consideration should be given to factors that can affect the INM’s calculation of maximum noise levels. This is discussed in the next section and the subsequent discussion of overall prediction uncertainties.

2.2.8 Meteorological Conditions

The meteorological conditions used in the assessment were sourced from the Bureau of Meteorology (BoM) website, based on the previous 5 years. The data has been used largely for determining the airport operational modes and the number of aircraft movements on each runway and flight path.

In addition to the above, local atmospheric conditions can also affect the calculated noise levels in two ways:

by varying the aircraft position (altitude influenced by air density); and

by varying the rate of absorption as sound propagates through the atmosphere.

Of these two, the change in the rate of atmospheric absorption generally has the largest effect on the noise levels, particularly when considering the calculation of short term noise metrics such as maximum noise levels. In this respect, it is important to note that seemingly minor changes in calculated noise levels can translate to relatively large changes in the size of noise contours, owing to the distances associated with aircraft noise contours.

The INM enables atmospheric absorption to be factored in one of the two following ways:

adopting default atmospheric absorption values: these default values do not correspond to any specific temperature or humidity. Instead, the default values are an average of varied absorption conditions relating to noise certification testing throughout Europe and the US; or

adopting user defined atmospheric values: a single set of average temperature and humidity values are entered by the user for each modelled scenario and INM applies the corresponding atmospheric absorption values.

The noise modelling description in the technical noise report does not explicitly comment on whether default or user defined atmospheric conditions have been accounted for in this aspect of the calculation. However, the stated meteorological conditions do not reference the humidity values that are needed to set user defined atmospheric absorption values. Accordingly, it appears that the default INM atmospheric absorption values have been used which result in lower predicted noise levels.

Previous discussions with Airservices Australia have suggested it is appropriate to adopt user defined atmospheric values where the appropriate environmental parameters are available. They did however note that this was as a conservative approach, which they considered appropriate. Furthermore, the FAA note that the user defined atmospheric values should be used to account for study specific weather conditions, especially when considering specific time periods as opposed to the annual average day.

Accordingly, to account for the variability of short term noise events, and the fact INM is not specifically intended for predicting short term noise events, the adoption of user defined site-specific atmospheric absorption values is generally preferable to default conditions.


2.2.9 Uncertainties

The combined uncertainty of the noise modelling data relates to the net effect of the various calculation settings and choices adopted for the study. Specific values of calculated uncertainty are not provided in the technical noise report. Instead, uncertainty has been addressed through the selection of conservative model input choices in most instances. This is considered a reasonable approach.

However, the following points are noted:

Information should be provided to support the reliability of the overall prediction methodology and choices for predicting maximum noise levels. This should ideally include details of measurement and prediction comparisons that have been used to validate the INM for predicting maximum noise levels. For example, comparison of available noise information from the Sydney Airport Noise Flight Path and Monitoring System or bespoke surveys. Further detail should also be provided concerning the manner in which atmospheric conditions have been accounted for in the noise predictions.

The largest source of uncertainty is the indicative flight paths which do not represent the final flight paths which would be flown if the project proceeds. A more detailed analysis on the extent of uncertainty in predicted noise levels due to flight path variation should be provided, either by way of a sensitivity analysis or predicted noise levels for a selection of key flight paths that could change as part of the detailed airspace design.

2.3 Noise Prediction Data

2.3.1 Airport operating modes

Noise prediction information for the Stage 1 development has been provided for a number of operating modes, primarily driven by the prevailing wind direction at the time.

Matters relating to the suitability of the operating modes are considered in a separate peer review of the airport operations described in Volume 1 Chapter 7 airspace architecture.

The operating strategies that have been modelled are generally considered appropriate. However, the following observations are noted:

Each of the preferred operating strategies includes the use of both runway modes i.e. mode 05 and mode 23. It is expected that the component of movements associated with each mode has been determined on the basis of a statistical analysis of 5 year Bureau of Meteorology data that is referred to in the technical noise report. However, the technical noise report does not specify the component of movements associated with mode of each preferred operating strategy, nor does the report specify how the components were derived.

The technical report does not present information about how frequently each of the operating strategies would be used, nor is there any information presented to demonstrate whether or not certain times of day would be more or less likely to favour particular operating strategies.

The modelling assumes the use of a head to head operating strategy comprising arrivals on runway 05 and departures on runway 23 would be viable. However, Volume 1 Chapter 7 Airspace architecture indicates the viability of head to head operations is yet to be confirmed, noting the following at Section 7.5:

A third operating mode, ‘head to head’ may be feasible following further detailed assessment prior to the commencement of operations. This would involve all landings and take off movements occurring in opposing directions, either to or from the south west; or to or from the north east.


2.3.2 Calculation Metrics and Scenarios

The Stage 1 noise chapter and technical noise report present aircraft noise information in a range of alternative formats, consistent with established government guidance.

The choice of metrics and scenarios are generally appropriate for defining the extent of areas which would potentially be affected by the noise of the assumed Stage 1 operating scenario. In all cases, noise contours do not represent the absolute extent of audible noise which an individual may find unsatisfactory, however this is not a practical objective for a noise assessment.

The following provides a discussion of the key forms of information that have been provided in the technical noise report for the assessment of noise impacts. Further information on the applicability of these metrics is provided in Section 2.4.1 of this review.

Number Above (NA) Ratings

NA ratings represent the number of times that aircraft events are predicted to exceed specified noise levels in a specified time period. The specified noise levels used in the technical noise report are 70 dB LAmax and 60 dB LAmax, resulting in calculated N70 and N60 values for different time periods on a typical busy day.

These values are generally appropriate. The draft EIS also usefully introduces the 90th percentile Number Above ratings as a way of representing the upper N60s and N70s that would be expected to occur in practice.

However, the following observations are noted:

The 60 dB LAmax lower threshold is generally suitable for assessing noise in urban areas. However, for the assessment of amenity impacts in quiet locations where natural soundscapes are valued, such as the Blue Mountains, lower predicted noise levels would be informative. It is acknowledged that the uncertainties associated with the prediction method increase with distance, meaning the lower values of predicted noise levels are subject to a greater degree of uncertainty. However, the alternative form of information relating to track density plots is not without compromises and is potentially more difficult to properly interpret – particularly given that the noise contours at the low levels extend considerably further than the width of the flight paths used to portray flight density tracks.

The information concerning the number of events exceeding key thresholds of 60 dB LAmax and 70 dB LAmax is generally only provided as 24-hour average or night-time values, with additional periods selected for assessing recreation areas. While this information is useful, further data to address the number of events expected to occur during specific time periods could provide a useful indication of impacts during sensitive times.

Single event combined maximum noise level contours

Single event maximum noise levels are provided for the loudest and most common aircraft, being the Boeing 747-400 and Airbus A320 aircraft, respectively.

It is noted that the ‘combined’ contour refers to the worst case scenario of a single noise event occurring on each of the tracks used by the aircraft i.e. where a departure track splits into 2, the maximum noise level considers noise on both tracks, thus providing an overestimate of the maximum level from a true single event. This generally provides a conservative representation of the extent of areas that could experience maximum noise levels of a given value, however the approach also introduces artefacts into the contours which are evident as a ‘comb’ effect on the contour lobes, artificially suggesting lower noise levels at some positions at the extent of the contours.


Australian Noise Exposure Concept (ANEC)

An ANEC is provided for each operating mode. The ANE metric is an exposure based noise metric, used solely for land use planning in Australia. The ANEC contours presented for Stage 1 provide limited information in regards to land use planning, as these would typically consider longer term, ultimate capacity scenarios. However, the ANEC can be useful in understanding noise exposure around an airport. A number of studies, including the study upon which the ANE was based, have determined a relationship between noise exposure around an airport and community annoyance. This type of information is not provided in the technical noise report, and further discussion is provided in Section 2.4.3 of this review.

Summer/winter variations

The potential changes in noise contour extents between summer and winter are considered in the appendices of the technical noise report. The analysis generally shows minor change in predicted noise levels. However, as per the discussion in Section 2.2.8, it is unclear if the predictions include an account of varied atmospheric conditions for different times of year.

2.4 Impact Assessment Methodology

Environmental noise may result in a number of different direct and indirect impacts. The draft EIS addresses the range of impacts as follows:

Assessment of the extent of the potential aircraft noise impacts within the Stage 1 noise chapter and technical noise report on the basis of a range of modelling scenarios and metrics used to present aircraft noise information; and

Assessment of the effect and significance of these impacts in other sections of the draft EIS related to:

Health

Land use

Social

Property values

The separation of assessments in this way is not an uncommon approach, particularly given the assessment of the effect and significance of noise impacts often requires specialist knowledge beyond the areas of expertise of acoustic consultants. However, a complete appreciation of noise related impacts therefore requires reference to a range of distributed sections throughout the draft EIS.

Accordingly, while the noise chapters (Stage 1 and long term development) and technical noise report provide the primary basis for the comments in this section of the peer review, additional comment is provided in the following sections in relation to technical noise matters as they are presented in the assessment of noise effects in other chapters and specialist reports.

2.4.1 Methodology Overview

The Stage 1 noise chapter and technical report present predicted noise levels in the form of noise contours and population counts to demonstrate the potential extent of areas that may be affected around the proposed airport. The noise contours are supplemented by additional information such as flight track density maps which illustrate the patterns of overflights beyond the extent of the predicted noise contours.


The predicted noise level information presented in the draft EIS is consistent with the types of aircraft noise information recommended in a number of Federal government publications. Further, the contours generally extend down to relatively low noise levels and event numbers to demonstrate the extent of potential effects well beyond ANEC contours. This approach is considered appropriate.

However, the following key observations are noted:

The illustrated extent of the noise contours is generally considered to be an accurate representation for the assumed Stage 1 operations. However, the uncertainties relating to these assumed Stage 1 operations appear to be significant. The extent to which the Stage 1 airspace design may change is not prescriptively defined in the draft EIS; accordingly, the potential change to the extent of the predicted noise contours has not been defined. An indication of the potential changes to the extent of the contours is partly evident from the various operating modes that have been included in the prediction scenarios. It is however unclear if these represent the maximum extent of the noise contours which could be expected for the final airspace design. The example noted earlier in Section 2.2.3 regarding the departure track from runway 05 illustrates how the final airspace design may significantly alter the areas affected.

The aircraft movement numbers in the assumed Stage 1 operating conditions are linked to a specific point in time related to the definition of the initial stage of development. The duration of this initial stage of development is linked to one of the incremental milestones in the longer term periodic approval and management framework for the proposed airport. In this respect, the movement numbers do not relate to a specific point in time at which movement numbers are stable or do not change significantly. Accordingly, the contours represent a snapshot of the extent of affected areas at that particular point in time, while the actual extent of areas affected will continually change and expand over time.

The predicted N60 and N70 noise data are important metrics used to demonstrate a broader extent of impact than exposure metrics such as the ANEC. These values are specifically referenced for:

Indoor noise assessment: quantifying the number of external events which would give rise to internal noise levels inside a home with partially open windows which could potentially interfere with conversation or exceed thresholds commonly used for the assessment of sleep disturbance; and

Outdoor noise assessment: quantifying the number of events which could interfere with conversational voice levels or require a raised voice for conversation to be understood. This is however specifically only noted in relation to recreation areas (see section 3.7 of the technical noise report), rather than as a general consideration for the external amenity of residential settings.

The above considerations mean that the extent of impacts illustrated by the N60 and N70 contours is primarily focussed on matters of indoor amenity or external speech interference. As per the discussion of the Greater Blue Mountains area in Section 7 of the technical noise report, noise impacts in quiet outdoor areas where natural soundscapes are valued (whether these are public or private outdoor areas) will occur at levels below 60 dB LAmax. The impacts to these types of locations therefore extend beyond the N60 and N70 contours and reference must be made to alternative forms of supplementary information such as the track density maps presented for the Greater Blue Mountains.


Noise contour information is presented in terms of ANEC data and NA values for alternative operating configurations including preferred operating strategies such as Prefer 05 (runway strategy favouring movements directed from the southwest and toward the northeast) and Prefer 23 (runway strategy favouring movements directed from the northeast and toward the southwest). It is evident from the noise contours that the Prefer 05 and Prefer 23 scenarios include movements occurring in both directions. For example, this is most evident on figures for scenario Prefer 05. These figures illustrate contour lobes extending to the northeast along the runway centre line, beyond the extent of the departure track, thus indicating the influence of an arrival movement on runway 23 (see example extract in Figure 2 below). Technically this is consistent with the definitions provided for Prefer 05 and Prefer 23. However, these contours may be prone to misinterpretation as single mode contours which illustrate the noise associated with movements occurring in single directions (and would extend further than the illustrated Prefer 05 and Prefer 23 strategy noise contours).

Figure 2: Extract from section 3 of the technical report illustrating the influence of mode 23 movements in the Prefer 05 operating scenario

2.4.2 Sensitive Receivers and Noise Exposure Data

Section 2.10 of the technical noise report notes that the noise sensitive receptors around the proposed airport site include residences, education facilities and health facilities.

The technical noise report subsequently provides noise data and assessments relating to residential receptors, in addition to data concerning sensitive uses in recreation areas and the Greater Blue Mountains World Heritage Area.

Contour lobe associated with arrivals on runway 23 Contour lobe associated with arrivals on runway 23


However, education facilities and health facilities are not directly referenced or assessed in the Stage 1 noise chapter or technical noise report. Instead, reference is made to alternative noise metrics which were calculated and subsequently assessed in the health report contained in the draft EIS. The predicted noise levels for these locations should be available in the Stage 1 noise chapter and technical noise report, in the same way that they have been provided for other types of noise-sensitive receiver locations such as recreational areas (i.e. including the predicted N60 and N70 values).

Section 2.10 of the technical noise report also describes information sources and methodologies which were used to calculate the number of residential receiver locations experiencing a given level of noise exposure. The data sources and methods used to develop these population statistics are considered appropriate for the application, and include an appropriate account of projected population increases in the areas surrounding the proposed airport. As noted previously however, these are based on a snapshot at the particular assessment point in time, while the actual extent of impacts and people affected will continually change and expand over time.

2.4.3 Community Annoyance Assessment

The Stage 1 noise chapter and technical noise report primarily quantify the extent of areas which may be affected by aircraft noise. The subject of potential community annoyance is separately discussed in the draft EIS chapters and technical reports concerning potential social impacts and health risk assessments.

The population statistics discussed in the preceding section provide a useful indication of the number of people who may be affected by aircraft noise to varying degrees. However, in isolation, this data does not provide an indication of the likelihood or significance of potential community reaction to aircraft noise levels as a result of annoyance.

The Health Risk Assessment presented in Volume 4 Appendix G provides the most discussion of potential annoyance, noting that annoyance is most prevalent community response in a population exposed to environmental noise. The Health Risk Assessment includes a discussion of a range of research studies concerning dose-response relationships between total noise exposure levels and the percentage of a community likely to be annoyed or highly annoyed. However, the Health Risk Assessment concludes the discussion of annoyance by stating that no quantitative assessment of annoyance was conducted as part of the study.

The assessment of potential community annoyance is ultimately a complex task for a development of this scale. Dose-response relationships of the types referenced in the Health Risk Assessment can be used with noise levels and population data to provide a quantitative measure of the potential reaction. The use of these established relationships to represent the reaction of a separate community exposed to aircraft noise must be used with caution. In particular, consideration must be given to the uncertainties associated with using community reactions observed at other airports to predict the reaction of a separate community, exposed to a new source of aircraft noise. This type of analysis does however provides an objective basis for comparing the impacts of alternative operating strategies and, more broadly, establishing the risk of community noise annoyance relative to other established international airports in Australia.

Accordingly, while the assessment of the risk of community annoyance is complex, the scale of the proposed airport, and the number of people potentially affected, are considered sufficiently large to warrant further evaluation of the subject. In particular, the introduction of a new 24-hour international airport at a greenfield development site ultimately represents a significant risk of wide spread and prolonged community annoyance.


A quantitative analysis of community annoyance is therefore considered appropriate to assess the significance of the impact. This analysis would also assist with determining the extent to which operational noise mitigation should be prioritised relative to other non-safety related airspace management considerations. Further consideration should therefore be given to quantitative analysis based on established response relationships. The scale of the project may also warrant consideration of further social surveys which could be used to establish a new dose response relationship which may be more relevant to the long term impacts on potentially affected communities around the proposed airport site. Other types of quantitative analysis could comprise population statistics and complaint trends for existing Australian airports which could provide contextual information about the sensitivity, or otherwise, of the proposed airport site relative to other established international airports in Australia.

Importantly, without a meaningful appraisal of the risks of significant community disturbance, there is the potential for unforeseen impacts and the associated risk of a requirement for reactionary noise management procedures. As well as the impacts to neighbouring communities, this could subsequently jeopardise the operational flexibility of the proposed airport.

2.4.4 Sleep Disturbance Assessment

The technical noise report provides information concerning sleep disturbance in terms of the number of events exceeding 60 dB LAmax for each operating mode during the night-time period 10 pm to 7 am. A level of 60 dB LAmax is cited as the external level which would approximately correspond to an internal level of 50 dB LAmax; an internal level that is commonly used as a design criterion for protection against sleep disturbance.

The selected assessment thresholds in the technical noise report are consistent with common industry practice for assessing sleep disturbance. In particular, the values are generally consistent with the advice contained in the World Health Organisation guidelines (Bergland et al, 2009) which also refers to an external level of 60 dB LAmax for the avoidance of sleep disturbance. The values are also similar to values referenced in NSW policies concerning road traffic. While the technical report does not specifically state the number of events exceeding 60 dB LAmax which are sufficient to represent an increased risk of sleep disturbance, the information is provided for a relatively low number of events (i.e. down to 5 – 10 events). For context, the WHO guidelines suggest that external noise levels exceeding these values should ideally not occur more than 10 to 15 times per night when assessing dwellings with partially open windows.

The technical noise report provides future population counts for this data indicating that between approximately 4,000 and 48,000 people could experience more than 5 events per night exceeding 60 dB LAmax, depending on operating strategy. In terms of areas experiencing a greater number of events, the technical noise report identifies between approximately 600 to 1,200 people experiencing 20 to 15 events per night above 60 dB LAmax, depending on operating strategy.

The key points from these figures are that:

A large number of people are predicted to experience external maximum noise levels which are sufficient to result in internal noise levels corresponding to sleep disturbance thresholds. In turn, this indicates a large number of people may need to sleep with windows closed to maintain an acceptable internal amenity. The extent of this potential impact would depend on the prevalence of existing ambient noise sources which could prompt an individual to sleep with closed windows, irrespective of the proposed airport.


As referred to in the technical noise report, the Prefer 05 strategy results in the greatest number of people experiencing more than 5 events per night over 60 dB LAmax , but the least number of people experiencing more than 20 events per night over . In the absence of established guidelines, or proposals in the draft EIS, to indicate whether priority should be given to reducing the number of people to a small number of events or reducing the number of people exposed to the highest number of events, it is unclear how these findings would inform the selection of noise mitigation measures or a preferred operating strategy.

The information is primarily directed at understanding noise impacts experienced by people in dwellings with partially open windows. The information does not indicate if there are dwellings which would experience night-time events that are sufficiently high in level to result in noise levels above the 50 dB LAmax internal criterion, even if the windows are closed. This type of information would provide an indication of the number of dwelling locations which could potentially require upgraded insulation to maintain an acceptable internal amenity.

In addition to the technical noise report, it is noted that Section 6.3.1 of Volume 4 Appendix G Community Health provides an assessment of sleep disturbance. The peer review of this document is being separately carried out be specialists in the field of health assessment and is therefore not reviewed in detail in this peer review document. It is however noted that while the Community Health report makes reference to the maximum noise level data contained in the technical noise report, the Community Health report primarily assesses impact on the basis of equivalent noise levels. Given that the 2030 assessment year involves a relatively low number of movements from the proposed airport (refer to earlier discussion of movement numbers in Section 2.2.5), some discussion of the rationale for focussing on equivalent noise levels instead of maximum noise levels would be prudent; particularly given that the Health Report acknowledges that the dose-response curves have been derived from European studies and may underestimate the impact in the area surrounding the Western Sydney airport site.

2.4.5 Land Use Impacts

The technical noise report presents Australian Noise Exposure Concept (ANEC) contours in section 3.6 titled Land Use Planning Impacts.

ANEC contours are not used for land use planning, but are normally presented as an indication of the potential extent of Australian Noise Exposure Forecast (ANEF) contours which are used for land use planning; the ANEF being an endorsed ANEC or combination of ANECs.

However, as acknowledged in the draft EIS, the ANEC contours presented for the Stage 1 proposal provides limited guidance in this instance, as the ANEF is normally derived from ANECs calculated for long term operations or ultimate capacity scenarios, rather than short term ANECs related to the initial phase of operation. Evaluation of land use planning impacts must therefore be based on the long term ANEC contours presented in subsequent sections of the technical noise report. These long term ANEC contours are discussed subsequently in Section 3.1.3 and Section 3.2.5 of this peer review report.


2.4.6 Dwelling Insulation

The Stage 1 noise chapter and technical noise report do not refer to requirements for, or proposals for, insulation of dwellings for the protection of internal amenity.

The potential for dwelling insulation is however mentioned in Volume 2 Chapter 28 Environmental Framework which notes the following:

the possible insulation or acquisition of buildings exposed to the highest noise levels having regard to Australian Standard 2021, including mechanisms for funding potential noise amelioration works and property acquisitions;

There is however no detail provided in the draft EIS in terms of quantifying the extent to which such measures would be implemented, or how the process of insulating or acquiring dwellings would occur ‘with regard to Australian Standard 2021’. The reference to AS 2021 for this application requires further clarification to understand the extent of areas that may be insulated or acquired. For example, it is unclear if dwelling insulation would only be considered within certain Australian Noise Exposure areas, or if such measures would be considered at all locations where internal levels may be expected to exceed AS 2021 internal design criteria as a result of the proposed airport operations.

2.4.7 General Recreation Areas

Section 3.7 of the technical noise report provides information relating to recreation areas. Separate information concerning the Blue Mountains is provided in section 7 of the technical noise report.

The assessment for these locations is primarily based on the number of events predicted to exceed 60 dB LAmax and 70 dB LAmax. The information and assessment procedures for these locations is considered appropriate, subject to the points noted in the technical noise report concerning the impact on acoustic amenity. Specifically, that the noise would be noticeable in areas used for passive recreation and the noise could be considered intrusive on the acoustic amenity.

2.4.8 Greater Blue Mountains World Heritage Area

The technical noise report provides an assessment of noise levels in the Greater Blue Mountains World Heritage Area (GBMWHA).

To provide a basis for assessing impacts to the GBMWHA, the technical noise report presents information in the form of track density plots. While this form of data provides a useful and established form of information, the reason for reverting to overflight numbers in lieu of predicted noise levels is not stated. As per the discussion in Section 2.3.2 of this peer review, this may be related to increased uncertainty in the predictions when considering low predicted noise levels. However, flight track density plots in isolation do not illustrate the full extent of potentially intrusive noise levels at locations to the side of the flight track.

The report notes that aircraft are typically at an altitude of approximately 5000 ft, which corresponds to a noise level on the ground of approximately 55 dB LAmax, consistent with INM predictions for the Airbus A320 or Boeing 737-800. Measurements at other airports have however demonstrated that aircraft at that altitude are generally higher than those predicted using the INM, and accordingly noise levels in practise could be higher.

As per the technical noise report, levels below 55 dB LAmax could be considered intrusive by recreational visitors and other users, as the natural soundscape is an important attribute of high value wilderness areas. While levels below 55 dB LAmax are likely to be comparable to typical levels associated with ambient noise sources in the GBMWHA, it is generally not considered appropriate to assess aircraft noise intrusion by comparing sound pressure levels; the characteristics of aircraft noise and natural sounds and very different, and are interpreted in very different ways.


The preservation of quiet areas and tranquil landscapes has been a topical subject of research and policy consideration in Europe and the US. For example, the US Transportation Research Board publication on the effects of aircraft noise (Mestre, 2008) includes a chapter which discusses research and US legislation (National Parks Overflight Act of 1987) concerning the effects of aviation noise on parks, open space and wilderness areas. These publications do not provide definitive guidance on assessment techniques, but highlight the complexity and importance of assessing aircraft overflight noise in sensitive wilderness areas.

The potential for a large number of audible events below 50 – 55 dB LAmax is therefore considered to represent a potentially significant and widespread impact within the GBMWHA. On this point, we note that the separate assessment of impacts to the GBMWHA presented in Volume 2 of the draft EIS indicates noise levels below 50 and 55 dB LAmax are ‘not significant’. Given the above, the assertion within draft EIS GBMWHA chapter that noise levels below 50 and 55 dB LAmax are ‘not significant’ is not considered to have been sufficiently justified, and the assessment may therefore not adequately reflect the potential impact to the values of tranquillity within the World Heritage Area.

Given the status of the Blue Mountains as a World Heritage Area, and the potential for intrusive impacts, further assessment of this sensitive receiver location is considered to be warranted. In particular, further information should be provided to demonstrate the relative merits of alternative aircraft arrival management procedures which do not involve a concentration of aircraft movements over the GBMWHA. This should include a discussion of the tradeoffs between protection of amenity in residential areas and the protection of the GBMWHA. Consideration should also be given to different areas within the GBMWHA noting any areas of increased recreational use or areas where tranquillity and natural soundscapes may be more valuable.

2.5 Alternatives

The EIS guidelines establish a requirement to investigate feasible alternatives for the proposal, including:

a) If relevant, the alternative of taking no action;

b) A comparative description of the impacts of each alternative on the matters of national environmental significance and other matters protected by controlling provisions of Part 3 of the EPBC Act for the action; and

c) Sufficient detail to make clear why any alternative is preferred to another.

The technical noise report considers the number of people potentially affected for alternative merge points in general terms. For the two alternative merge points considered, the technical noise reports notes that the flight densities over Blaxland are reduced, and the people affected are aligned to less populated rural residential areas outside the GBMWHA. Track densities and number of aircraft overflights over Blue Mountains’ communities are still predicted to be high, while impacts on some areas within the GBMWHA are increased for the two alternative merge points.

It is therefore unclear why preference has been given to the merge point that affects a greater population, i.e. over Blaxland, in lieu of reducing the number of potential affected residences. This is perhaps due to conservation of the world heritage area, however this should be confirmed.

Further, while the merge point system appears to offer some noise benefits related to the use of constant descent approaches, the merge point conversely results in concentrated impacts directly beneath the merge point. The considerations warrant an assessment of the noise of additional alternatives, in terms of alterative merge point configurations (e.g. multiple merge points as per the 2063 airpsace design in lieu of a single merge point), and in terms of alternatives arrival management procedures to the merge point system.


In broader terms, with the exception of the merge points noted above, no assessment of alternative flight tracks or noise mitigation procedures has been presented in the noise chapter or technical noise report. This is presumably related to the limited extent to which the airspace management design has been progressed, however this source of uncertainty is a key reason to consider the impacts of potential alternative procedures.

2.6 Proposed Mitigation Measures

The noise modelling presented in the Stage 1 noise chapter and technical noise report provides information concerning the following mitigation measures:

The use of continuous descent approaches for all arrival procedures; and

Relocation of the merge point associated with the Stage 1 proof of concept airspace design.

As discussed in Section 2.2.3 of this peer review report, the noise modelling is based on an indicative proof-of concept air traffic management design which does not present a comprehensive airspace and air route design, nor does it consider all of the essential components that would be necessary to implement an air traffic management plan for the Sydney basin.

Given the uncertainties concerning the final form of the airspace design, the final form of noise mitigation measures to be implemented is not yet known. Accordingly, the mitigation measures that have been referred to in the aircraft noise assessment are generic in nature. The residual noise impacts associated with the proposed airport’s operations following the implementation of such mitigation measures is therefore presently unknown.

To provide context, feasibility noise assessments and generic mitigation measures are not uncommon for other forms of infrastructure project for which there are well defined policies that limit the allowable noise that may occur in practice. In contrast, aircraft noise policies and regulations in Australia do not specify limits which apply to aircraft over overflight noise at surrounding sensitive receptor locations. Accordingly, without a defined airspace design or defined noise criteria to adhere to in practice, a defined noise mitigation strategy and the residual impacts and the location of these impacts is subject to considerable uncertainty. Further, without a defined noise limit, it is unclear how noise considerations would be prioritised among other non-safety related airspace management and operational considerations associated with the proposed airport site.

Based on the above considerations, further information about the likely airspace management plan, mitigation strategies or proposed control mechanisms (with reference to performance criteria) is considered essential. The discussion of mitigation measures should include:

Clarification of preferred operating strategies to manage environmental noise impacts, including reference to mitigation priorities and the manner in which alternative mitigation measures would be evaluated, e.g. is priority given to limiting the number of people experiencing the greatest noise effects or limiting the total number of people within the overall extent of the contours, and how will considerations related to residential and non-residential noise-sensitive receiver locations be balanced;

Clarification of how the flight paths and hence predicted noise levels may vary during the detailed design of the airspace management procedures;

Clarification of whether Noise Abatement Departure Procedures (NADP) as defined by ICAO would be considered in the noise management plan, and if so, under what circumstances or operating scenario. For example, would NADP be considered for all operations, operations on a given runway, or operations occurring at night;

Clarification of the proposal to implement a merge point arrival system;

Clarification of the proposal to implement head to head operations during night-time hours;


Clarification of the extent to which dwelling insulation or property acquisition measures would be implemented, or how the process of insulating or acquiring dwellings would occur ‘with regard to Australian Standard 2021’. For example, would such measures be limited to locations within the ANEC/ANEF 20 contour, or would dwelling insulation potentially extend to locations outside of the ANEC/ANEF contours to address internal noise levels at locations where noise levels above the design criteria in AS 2021 are not expected to be achieved. Consideration should be given to circumstances where a resident must close windows to protect internal amenity, or in instances where the noise levels are above the design criteria even with windows closed; and

Consideration of the potential merits of mitigation strategies tailored to the initial phase of operations when communities may be particularly sensitive to the presence of a new major noise source in the area. For example, this could include deliberate and staged incremental movement number increases to avoid ‘sudden’ noise exposure which has led to significant community reaction at some new airports, particularly in terms of night operations.


3.0 REVIEW FINDINGS – LONG TERM DEVELOPMENT

The following section discusses the noise impacts associated with the longer term development of the proposed airport, accounting for:

Longer term development of single runway capacity: incremental development of aviation infrastructure and support services to facilitate 164,000 aircraft movements per year which are projected to occur by 2050; and

Longer term development with an additional parallel runway to the south: an additional runway is proposed for long term operations, enabling additional capacity increases to 370,000 aircraft movements per year which are projected to occur by 2063.

A number of the considerations identified from the peer review of the Stage 1 development are directly relevant to the assessment of the long term development scenarios. For example, matters related to the noise prediction methodology are identical for the Stage 1 and long term development scenarios. Accordingly, this section details any variation to those assessed in the long term development scenarios.

3.1 2050 – Additional capacity single runway

3.1.1 Flight paths

The flight paths are as per the stage 1 development and accordingly the same findings apply. Specifically, they do not represent the final flight paths which would be flown if the project proceeds and the reports do not provide any indication of the manner or extent to which the final airspace design may vary from the proof-of concept design. This represents a significant source of uncertainty in the predicted noise levels.

The 2050 scenario also includes Boeing 747-400 stage 9 departures (i.e. a higher takeoff weight due to longer trip length). However, the proposed runway length of 3,700 m is noted to be less than the required runway length specified in Volume 1 Chapter 5 Airside Precinct (see Table 5-4) for a maximum weight Boeing 747-400 take off. This may be plausible if weight restrictions are applied to Boeing 747-400 departure operations. Irrespective, from a noise perspective, this suggests that the Boeing 747-400’s inclusion in the noise modelling may be conservative.

3.1.2 Movement numbers

The movement numbers for the 2050 scenario are consistent with forecasts for similar single runway Australian International airports (Perth, Adelaide), refer Figure 1. Accordingly, the predicted noise levels for this scenario would appear more suitable as the appropriate primary assessment scenario for the purpose of obtaining approval for the development.

These comments are provided primarily in relation to the plausibility of the movement numbers represented in the noise modelling, based on comparisons with the movement numbers documented in the noise modelling for other Australian international airports and similar time horizons. Aircraft traffic forecasts are however outside of our area of expertise and therefore the suitability of the specific movement numbers adopted for the 2050 noise assessment are considered in further detail in a separate aviation peer review commissioned by WSP Parsons Brinckerhoff.


3.1.3 Land use impacts

We note a difference in the population counts within ANEC bands for the 2050 scenario between the technical noise report and the long term development noise chapter. The source of this discrepancy is unclear. For reference, a sample of the differing values is presented in Table 2.

Table 2: Estimated population within ANEC contours (2050) for Prefer 23 with head-to-head

ANEC Data from Table 31-2 of

Volume 3

Data from Table 4-3 of the

technical noise report

20-25 1,293 1,672

25-30 302 379

30-35 72 77

>35 4 4

Total 1,672 2,132

3.2 2063 – Parallel runway

3.2.1 Runway position

The proposed second parallel runway would be located to the south of the proposed stage 1 development runway, with a separation distance of approximately 1,900 m according to Volume 2 (Section 30.2).

The specific location is not defined with reference to an aerodrome reference point, runway end coordinates or elevation details. The parallel runway orientation is assumed to be consistent with the Stage 1 proposal runway, i.e. a single southwest / northeast runway designated as runway 05R and 23L respectively. However, as per the discussion earlier in this peer review report in Section 2.2.1, it is unclear if the exact orientation of the runway has been finalised.

3.2.2 Departure tracks

The flight tracks depicted in Figure B1 of Appendix B of the technical noise report show that departures on runway 05R (parallel) turn left approximately 3 km from the runway end and head due north for 25 km before branching out to a number of directions. This flight path is similar to the track depicted for the initial runway of the Stage 1 development.

However, an additional departure track to the northeast is included in this scenario, and involves direct overflight of the relatively densely populated areas to the northeast, such as Blacktown. Further discussion of noise mitigation measures relating to this flight path would be prudent.

3.2.3 Cumulative impacts

Airspace architecture chapter of Volume 1 (Section 7.4.1) notes that under a parallel runway scenario at the proposed airport, a number of issues would need to be addressed as part of the future airspace design process, including:

changes to Sydney Airport flight paths to maintain independent operations at the proposed airport and Sydney Airport and to achieve expected demand capacity;

changes to flight paths serving Bankstown Airport, in particular for instrument flight rule operations, in order to maintain independent operations at the proposed airport and Bankstown Airport and achieve the expected demand capacity; and

resolution of a potential constraint associated with the restricted airspace over Defence Establishment Orchard Hills.


Section 5B of the EIS Guidelines requires the EIS to:

identify and address cumulative impacts, where potential project impacts are in addition to existing impacts of other activities (including known potential future expansions or developments by the proponent and other proponents in the region and vicinity)

The draft EIS has not considered implications on flight paths at other airports and the associated noise impacts on other communities closer to Sydney, Bankstown and Defence establishments having regard to the potential variation in the final flight paths. The issues concerning the airspace architecture are considered to represent potential cumulative impacts which have not been quantified in the draft EIS.

Further information concerning this issue is therefore considered necessary to address the requirements of the EIS guidelines.

3.2.4 Operating modes

The assessment considers two operating modes only, ‘prefer 05’ and ‘prefer 23’. The technical noise report notes that the use of alternative night time operating modes, such as ‘head to head’ as per the Stage 1 development could likely reduce night time impacts. This is not quantified and conclusions on the potential reduction in noise levels can therefore not be established.

Further, the discussions presented in Volume 1 Chapter 7 Airspace architecture indicate that the feasibility of head to head operations is yet to be confirmed.

3.2.5 Land use impacts and dwelling insulation

As per the assessment of the stage 1 development, the land use planning impacts in the technical noise report considers only the number of potential people within each ANEC band for each of the operating modes.

The ANECs prepared in the technical noise report for the long term development may be considered indicative of the extent of an ANEF for the proposed airport. The technical noise report does however note that an ANEF chart based on further formal flight path design would need to be produced and endorsed by Airservices Australia prior to the commencement of airport operations and to inform land use planning around the proposed airport.

The 1985 EIS prepared an indicative ANEC for the Western Sydney Airport. It is understood this ANEC formed the basis for zoning land uses around a future airport, as detailed in local environmental plans having regard to future aircraft noise. As such, there are current planning mechanisms in place to ensure future dwellings incorporate appropriate treatment in anticipation of the proposed airport.

The draft EIS has not fully undertaken an assessment of land use impacts. Specifically, an assessment of the location of current dwellings within ‘zones affected by aircraft noise’ documented in the local environmental plans (based on 1985 EIS ANEC contours) and their relative location based on the ANECs prepared as part of this EIS. Details on the change in the ANEC rating for individual dwellings would ideally be undertaken to determine the extent of further mitigation measures. Such measures may include potential dwelling insulation to dwellings where a significant change in ANEC has occurred.

Noting the ANECs prepared for this EIS are not final, consideration should still be given to the potential extent of a single ANEF to be adopted for future land use planning. Australian Standard AS2021:2015 Acoustics - Aircraft Noise Intrusion – Building Siting and Construction, details procedures for the preparation of an ANEF. Specifically, where future runways are proposed, a composite chart of a number of ANECs should be produced to cover areas the single runway at ultimate capacity ANEC are not covered by adopting the ANEC incorporating the 2 runways.


A complete assessment should therefore be undertaken with the above considerations, to enable a complete understanding of the potential land use impacts associated with the airport operations.

In addition to the above, the technical noise report does not discuss the potential land use planning impacts related to the National Airports Safeguarding Framework (the Framework) which was developed by the National Airports Safeguarding Advisory Group in 2012. This Framework is however noted in the noise chapter, which subsequently refers readers to Chapter 21 Planning and land use for further information.

The Framework provides guidance on planning requirements for development that affects aviation operations. As part of the guidance, the Framework proposes the use of new noise metrics for land use planning, subject to the outcomes of a review of Australian Standard AS 2021. The review of AS 2021 was completed and the revised version of AS 2021 published in May 2015. While the revised standard did not include the additional land use buffers that were requested by the National Airports Safeguarding Advisory Group (i.e. the updated version of AS 2021 continues to refer to solely to the ANEF parameter rather than Number Above metrics), it is noted that an amendment to Victorian Planning Provisions (see VC128) was scheduled by the Victorian government on 8 October 2015 to include the National Airports Safeguarding Framework as a policy guideline. This policy only applies in Victoria and it is unclear how this new guidance will affect land use planning around Victorian airports. However, the introduction of the Framework into a state policy provides a precedent for the potential use of noise contours extending well beyond ANEC contours to inform land use planning.

Further, while the Framework is not directly referenced in the noise chapter or technical noise report, the Framework is introduced in Volume 2 Chapter 21 Planning and land use. The peer review of this document is being separately carried out by specialists in land use planning and is therefore not reviewed in detail in this peer review document. It is however noted that 21.7.2.2 focuses on the implications of a future ANEF for land use planning, but concludes with the following statement:

The implementation of Guideline A: Measures for Managing Impacts of Aircraft Noise under the NASF would be instrumental in managing potential future operational noise impacts for future land use planning and development around the airport.

This would appear to imply the potential for land use planning instruments extending well outside of the future ANEF contours, despite land use impacts outside of the ANEC/ANEF contours not being specifically cited in the discussion. This is reinforced by content in Volume 2 Chapter 27 Cumulative Impact Assessment which states:

The draft EIS provides ANEC contours and identified other potential noise impact areas which can be used to guide appropriate future land use planning and compatible development.

The imposition of the Framework for land use planning around the proposed airport could therefore result in land use impacts extending well beyond the existing land use controls or a future ANEF developed during the detailed design phase of the airport. The potential for these extended impacts should be clarified and clearly disclosed.


4.0 SUMMARY

A peer review of the aircraft overflight noise assessment contained within the draft Environmental Impact Statement (draft EIS) for the proposed Western Sydney Airport has been carried out.

The noise modelling is considered to generally provide an accurate representation of the extent of noise impacts for the development description and operating scenarios that have been proposed. However, the peer review has identified a number of limitations which relate to both the extent to which the airspace management’s design has been progressed, and the assessment of the noise modelling outcomes. These matters are summarised as follows:


The total aircraft movement numbers for the Stage 1 development are relatively low when compared to other international airports in Australia. Given the objective of the proposal is to develop a major international airport, the low movement numbers raises the question of the suitability of the 5 year time horizon as the appropriate primary assessment scenario for the purpose of obtaining approval for the development. Further, it is unclear how the incremental and periodic approvals that would need to occur as part of the ongoing expansion of the airport provides a sufficient basis for considering the initial 5 years of operation as the primary period for the assessment of noise impacts.

These comments are provided primarily in relation to the plausibility of the movement numbers represented in the noise modelling, based on comparisons with movement numbers documented in the noise modelling for other Australian international airports and similar time horizons. Aircraft traffic forecasts are however outside of our area of expertise and therefore the suitability of the specific movement numbers provided for the noise assessment are considered in further detail in separate aviation peer review commissioned by WSP Parsons Brinckerhoff.


the draft EIS clearly indicates that the airspace management strategy used as the basis for noise modelling is a proof-of concept design, and further work is required to determine the actual flight paths which would be flown in practice. Information about the extent of potential changes is limited. The uncertainty surrounding the final airspace management design that would be implemented represents a potentially significant source of uncertainty in the noise assessment. The potential significance of this source of uncertainty has not been quantified and, with exception of alternative merge point points for Stage 1, there has not been any sensitivity analysis carried out to assess the implications of potential flight path changes.


The draft EIS includes exposed population statistics which provide a useful indication of the number of people who may be affected by aircraft noise to varying degrees. However, in isolation, this data does not provide an indication of the scale or severity of potential community reaction to aircraft noise levels as a result of annoyance.

The Health Risk Assessment provides the most discussion of community annoyance, including references to research concerning the relationship between noise exposure and community annoyance, but ultimately states that no quantitative assessment of annoyance was conducted as part of the study.


Dose-response relationships of the types referenced in the Health Risk Assessment can be used with noise levels and population data to provide a quantitative measure of the potential reaction. The use of these established relationships to represent the reaction of a separate community exposed to aircraft noise must be used with caution. In particular, consideration must be given to the uncertainties associated with using community reactions observed at other airports to predict the reaction of a separate community to a new source of aircraft noise. However, this type of analysis provides an objective basis for comparing the impacts of alternative operating strategies and, more broadly, establishing the risk of community noise impacts relative to other established international airports in Australia.

Accordingly, while the assessment of the risk of community annoyance is complex, the scale of the proposed airport, and the number of people potentially affected, are considered sufficiently large to warrant further evaluation of the subject. In particular, the introduction of a new 24-hour international airport at a greenfield development site ultimately represents a significant risk of wide spread and prolonged community annoyance.

A quantitative analysis of community annoyance is therefore considered appropriate to assess the significance of the impact. This analysis would also assist with determining the extent to which operational noise mitigation should be prioritised relative to other non-safety related airspace management considerations. Further consideration should therefore be given to quantitative analysis based on established response relationships. The scale of the project may also warrant consideration of further social surveys which could be used to establish a new dose response relationship and may be more relevant to the long term impacts to potentially affected communities around the proposed airport site.

Land use impacts

The draft EIS includes calculated Australian Noise Exposure Concept (ANEC) contours for the Stage 1 and long term development operating scenarios. ANECs are often presented as an indication of the extent of a potential future Australian Noise Exposure Forecast (ANEF) contour which would be used to guide land use planning for noise-sensitive developments in the vicinity of airports.

However, while the draft EIS provides population counts for the various ANEC bands, no assessment is provided of the extent to which land use controls may change as a result of a future ANEF prepared as part of the detailed airspace design for the project. Specifically, the draft EIS does not quantify the potential extent of changes to land use controls relative to the measures which have been in place since the original EIS was undertaken in 1985.

Furthermore, the discussion of land use planning impacts in the draft EIS notes that the National Airports Safeguarding Framework (the Framework) would ‘be instrumental in managing potential future operational noise impacts for future land use planning and development around the airport’. The Framework could potentially translate to the creation of land use planning controls which extend over significantly greater areas than either the current land use planning controls (based on the 1985 EIS) or the 2063 ANEC contours provided in the draft EIS. This has however has not been discussed or assessed in the draft EIS.


Greater Blue Mountains World Heritage Area (GBMWHA)

The draft EIS presents information to evaluate the potential impacts of aircraft operations on the acoustic amenity of the GBMWHA. The assessment indicates the potential for a large number of audible aircraft events within the GMWHA. While the levels are predicted to be relatively low (below 50 – 55 dB LAmax), aircraft over flights would be expected to be audible and represent a significant and widespread impact for a World Heritage Area where natural soundscapes are a likely to be a valued feature of the areas amenity. Accordingly, the assertion within draft EIS chapter that noise levels below 50 and 55 dB LAmax are ‘not significant’ is not considered to have been sufficiently justified, and the assessment may therefore not adequately reflect the potential impact to the values of tranquillity within the World Heritage Area.


The draft EIS noise modelling is based on an indicative proof-of concept air traffic management design which does not present a comprehensive airspace and air route design. Given the uncertainties concerning the final form of the airspace design, the final form of noise mitigation measures to be implemented is not yet known. Accordingly, the mitigation measures that have been referred to in the aircraft noise assessment are generic in nature. This is a particularly important point for an airport development as, unlike other forms of infrastructure development, the policies used to manage aircraft overflight noise do not generally stipulate noise limits that airport operations must adhere to at surrounding noise-sensitive locations. Accordingly, without a defined airspace design, a defined noise mitigation strategy or defined noise criteria to adhere to in practice, the residual impacts and the location of these impacts is subject to considerable uncertainty. Further, it is unclear how noise considerations would be prioritised among other non-safety related airspace management and operational considerations associated with the proposed airport site.

Based on the above considerations, further information and assessment are considered necessary before stakeholders can reach an informed view on the potential scale and significance of aircraft overflight noise impacts associated with the proposed airport site.

Conclusion

Aircraft noise impacts are an unavoidable consequence of aircraft operations in urban environments. The creation of a new international airport therefore requires a balance to be achieved between the protection of amenity for neighbouring sensitive land uses and the development of infrastructure to respond to the growing demands of a major city.



Provide clarity to affected communities and stakeholders about the nature of the noise impacts;

Provide clarity to regulators about the form of noise controls which will be needed in the project approval to ensure that noise is appropriately managed; and

Reduce the potential for unforeseen impacts and the associated risk of reactionary noise management procedures which could subsequently jeopardise the operational flexibility of the proposed airport.


5.0 MDA PEER REVIEW PERSONNEL

The following personnel from Marshall Day Acoustics have conducted this peer review on behalf of WSP Parsons Brinckerhoff.

Engineer and role Qualifications and key relevant experience

Justin Adcock,

Lead Peer Reviewer

Bachelor of Engineering (Mech), University of Adelaide, South Australia

Department of Defence, New Air Combat Capability: Contract and technical manager for the environmental noise modelling and impact assessment of Joint Strike Fighter operations - lead author of the noise impact assessment.

Dubai International Airport and Jebel Ali International airport: Noise modelling, model validation works and impact assessment– lead report author. Alex Morabito,

Peer Reviewer

Bachelor of Engineering (Mech), University of Adelaide, South Australia

Bachelor of Finance, University of Adelaide, South Australia

Department of Defence, New Air Combat Capability: environmental noise modelling and impact assessment of Joint Strike Fighter operations

Adelaide Airport Noise Insulation Program: Compliance testing to verify acoustic design of churches eligible for program

Steve Peakall

Peer Reviewer

Bachelor of Science (Environmental Engineering), University of the West of England, Bristol, UK

Institute of Acoustics, Diploma in Acoustics and Noise Control

Sydney Airport, Peer review of the INM inputs for ANEF contours presented in the 2009 and 2013 Sydney Airport Master Plans.

In addition to the above main peer review personnel, review of key issues has also been provided by the following Marshall Day Acoustics.

Engineer and role Qualifications and key relevant experience

Christopher Day

Bachelor of Engineering (Mech), Monash University, Melbourne

Christchurch International Airport: Ongoing involvement since 1992 including, initial modelling and update of noise contours, presentation of expert evidence, member of the International Expert Panel, review of noise monitoring strategy and engine testing noise assessments.

Auckland International Airport: Extensive involvement for more than 23 years involving the preparation of noise contours, assessment of aircraft noise effects, noise management and land use planning and development of a sound insulation programme.

APPENDIX A GLOSSARY OF TERMINOLOGY

Ambient The ambient noise level is the noise level measured in the absence of the intrusive noise or the noise requiring control. Ambient noise levels are frequently measured to determine the situation prior to the addition of a new noise source.

ANEC A contour map showing forecast of aircraft noise exposure around an aerodrome for a future year. It is based on a forecast of aircraft movement numbers, operating times, types, destinations and flight paths

ANEF A reviewed and endorsed ANEC by Airservices Australia or Department of Defence. It is the only contour map with status in land use planning decisions for aircraft noise exposure

ANEI A contour map based on historical data from a previous year, where the numbers and types of aircraft which used the aerodrome are known. The map provides the average daily aircraft noise exposure around the aerodrome for that year. ANEI are typically used as benchmarks or an indicator of change in aircraft noise exposure

A-weighting The process by which noise levels are corrected to account for the non-linear frequency response of the human ear.

dB Decibel. The unit of sound level.

Feet (ft) Unit length 0.3048 m

Frequency The number of pressure fluctuation cycles per second of a sound wave. Measured in units of Hertz (Hz).

Integrated Noise Model (INM)

A computer program used to model the impact of aircraft noise developed by the US Federal Aviation Administration

LAeq The A-weighted equivalent continuous sound level. This is commonly referred to as the average noise level and is measured in dB.

LAmax The A-weighted maximum noise level. The highest noise level which occurs during the measurement period.

APPENDIX B REFERENCES

Airservices Australia, 2012. Continuous Descent Approaches. [ONLINE] Available at: http://www.airservicesaustralia.com/environment/continuous-descent-approaches/

Society of Automotive Engineers, 1986, Committee A-21, Procedure for the Computation of Airplane Noise in the Vicinity of Airports, SAE-AIR-1845

Society of Automotive Engineers, 1991, Standard Values of Atmospheric Absorption as a Function of Temperature and Humidity, SAE-ARP-866A

Standards Australia 2015, Acoustics-Aircraft noise intrusion-Building siting and construction, AS 2021-2015, Standards Australia, Sydney

Mestre, V, 2008, Synthesis 9 - Effects of Aircraft Noise: Research on Selected Topics, Washington, D.C: Airport Cooperative Research Program by the US Transportation Research Board

Berglund B, Lindvall T and Schwela DH, 1999, World Health Organization Guidelines for Community Noise

European Civil Aviation Conference, December 2005, ECAC-CEAC Doc 29 3rd Edition, Report on Standard Method of Computing Noise Contours around Civil Airports Volume 2: Technical Guide

http://www.airservicesaustralia.com/environment/continuous-descent-approaches/

Appendix BGround-based noise and vibration (WSP | Parsons Brinckerhoff)

Western Sydney Airport EIS Ground-based noise and vibration assessment peer review

19/11/2015

Project no: ACG1517900 Date: 19/11/2015

Prepared for: WSROC – WSP | Parsons Brinckerhoff Level 1, 41 McLaren Street North Sydney New South Wales 2060 Australia Tel: +61 (02) 8907 0900 Fax: +61 (02) 9957 4127 [email protected] WSP | Parsons Brinckerhoff Contacts: Alex Campbell Mike Barrett

Western Sydney Airport EIS Ground-based noise and vibration assessment peer review

mailto:[email protected]

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Quality Management

Issue/revision Issue 1 Issue 1 Revision 1 Revision 2

Remarks Draft Final

Date 6/11/2015 19/11/2015

Prepared by M. Barrett/C. Marsh M. Barrett/C. Marsh

Signature

Checked by A. White A. White

Signature

Authorised by A. Campbell A. Campbell

Signature

Project number ACG1517900 ACG1517900

Report number 1 1

File reference Draft Final

Project number: ACG1517900 Dated: 2015-11-06 4 | 44

Table of Contents Executive summary ........................................................................... 5

1 Scope ........................................................................................ 7 1.1 Summary of approach ........................................................... 7 1.2 Limitations ............................................................................. 8

1.3 Components of the EIS reviewed .......................................... 8 1.4 Policy and guidance .............................................................. 9

2 Detailed findings - 1st stage airport .......................................... 10 2.1 Summary ............................................................................. 10

2.1.1 EIS Guidelines ............................................................... 10

2.1.2 Assumptions .................................................................. 10

2.1.3 Conclusions ................................................................... 10 2.1.4 Mitigation and management measures proposed .......... 10

2.1.5 Uncertainty of impacts and environmental risks ............ 11 2.2 Detailed findings .................................................................. 11

2.2.1 Introduction .................................................................... 11 2.2.2 Scope ............................................................................ 11

2.2.3 Baseline noise survey .................................................... 11 2.2.4 Criteria ........................................................................... 15

2.2.5 Noise modelling ............................................................. 17 2.2.6 Assessment ................................................................... 19 2.2.7 Mitigation ....................................................................... 21

2.2.8 Cumulative assessment ................................................. 21 2.2.9 Conclusions ................................................................... 22

3 Detailed findings - long term development .............................. 23 3.1 Summary ............................................................................. 23

3.2 Detailed findings .................................................................. 23 3.2.1 Modelling ....................................................................... 23 3.2.2 Assessment ................................................................... 26 3.2.3 Conclusions ................................................................... 26

4 Key impacts and opportunities ................................................ 27

5 Qualifications of the study team .............................................. 28 5.1 Project manager .................................................................. 28 5.2 Supporting technical team ................................................... 28

Appendix A Document review ..................................................... 29

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Executive summary

Introduction

The Western Sydney Airport draft Environmental Impact Statement (EIS) was prepared to provide an assessment of environmental impacts associated with the development of a new international airport near Badgerys Creek in Western Sydney, NSW. The draft EIS contains an assessment of noise impacts in two components; noise impacts from air-based activities such as aircraft in flight, landing and take-off; and from ground-based activities such as aircraft taxiing and ground based engine run-up. This review is concerned with ground-based activities only.

Scope of review

This scope of this report is to provide an unbiased peer review of all work presented as part of the Western Sydney Airport draft EIS in relation to ground-based noise.

Approach

This review identified uncertainties and unknowns within the ground noise the assessment, provided in the EIS and identified what further assessment would be required to provide an indication of impacts. The limitations of this review are as follows:

■ Noise modelling or review of noise modelling files has not been completed as part of this review. Therefore it was not possible to verify the noise contour plots from ground-based activities presented in the EIS. However, comment has been included based on a visual inspection of the plots.

■ The review relies on the source noise data that has been included in the ground noise assessment. The review is a desktop exercise and therefore independent source noise measurements have not been conducted to confirm the noise levels used for taxiing and engine ground running as presented in the EIS.

The components of the review are follows:

■ The review comments on the EIS chapters relevant to ground noise in addition to Appendix E2 – Airport ground-based noise and vibration. This appendix is the technical basis for all other ground noise related documents, including the relevant EIS chapters.

■ A document review is contained within Appendix A of this report, and provides references and comment on specific sections of the EIS. The documents reviewed are identified in Section 1.3 of this report.

1st stage airport review findings

A summary of the findings for the 1st stage airport is as follows:

■ The assessment does not fulfil the requirements of the Guidelines for the Content of a Draft Environmental Impact Statement – Western Sydney Airport 2015 (EIS Guidelines). These guidelines state that the type and magnitude of impact, both pre-mitigation and post-mitigation should be presented. The ground noise assessment should be updated to include this assessment.

■ There is insufficient detail to satisfy the EIS Guidelines on the source of the noise data and assumptions used in noise predictions. As these assumptions form the basis for the noise assessment, changes to the source noise data could potentially lead to a significantly different outcome.

■ The assessment does not provide sufficient justification to support the assessment being performed based on the year 2030 (five years after opening) and not 2050 when the airport is expected to be approaching capacity for the single runway configuration with potentially increased noise impacts.

■ The report does not provide sufficient detail in the assessment of the ground-based power supply to aircraft when they are parked. The assessment excludes the use of Auxiliary Power Units (APU), however it does not provide sufficient detail of alternative ground-based power supplies. As an alternative power supply method is not presented, there is potential for additional noise sources being introduced that have not been considered.

■ Background noise monitoring was conducted at 10 locations in the region, however a single background level has been assumed for all receptors, rather than several location-specific values. This generalisation


has underestimated the assessment noise criteria and therefore the magnitude of noise impacts at receptors close to the airport that are currently exposed to low levels of environmental noise.

■ The nearest noise sensitive receptors in Luddenham were not included in the background noise monitoring and therefore there it is uncertain if noise impacts have been adequately assessed at this location.

■ No consideration has been given to the cumulative noise impact from all ground noise sources at the nearest noise sensitive receptors both with and without mitigation measures as required by the EIS Guidelines. Additional assessment should also be undertaken for other ground noise sources, such as the compass calibration pad.

■ It is recommended that the mitigation measures identified in the assessment, including the restriction of APUs and the limitation of engine ground run-ups during the night, are formalised as part of the project approval.

■ The assessment does not provide sufficient evidence that all reasonable and feasible mitigation measures have been considered to reduce noise impacts from taxiing and ground run-ups.

■ Semi-enclosed pens and bunded areas to reduce noise impacts from engine ground run-up noise are considered in the assessment. It is recommended that these measures are considered further as part of the approvals and subsequent design stages.

■ No comment has been made on the potential cumulative noise impact from the new M12 motorway and realignment of The Northern Road that are being developed to accommodate the airport.

■ The EIS contains misleading statements relating to operational road traffic noise which do not acknowledge the limitations of the assessment. The development of the M12 motorway and realignment of The Northern Road have been excluded from the assessment and statements regarding operational road traffic noise should include these limitations.

Long term development review findings

■ The assessment is considered to contain an appropriate level of detail for the long term development as the potential noise impacts are predicted for a considerable time in the future (into 2063). It is acknowledged that the noise environment may change over time.

■ The comments raised in this review for the 1st stage airport assessment should be addressed and applied to the long term development assessment. Where this occurs, the current framework for further assessment of the long term development is considered appropriate.

■ The EIS does not include ground-based noise in the summary or conclusion for the long term development. It is recommended that the outcomes of the revised long-term development ground-based noise assessment are included in these sections so that all impacts are clearly presented.

Key impacts and opportunities

It is considered that the ground-based noise assessment does not provide an appropriate level of detail on a number of key aspects including:

■ The derivation and allocation of assessment criteria

■ Noise impacts at the nearest sensitive receptors in Luddenham

■ Noise source levels and modelling assumptions

■ The type and magnitude of impacts with and without mitigation

■ Evidence that all reasonable and feasible mitigation has been considered

■ Cumulative noise impacts from operational activities and road traffic projects.

As a result, without further clarification or justification, it is uncertain that the draft EIS has adequately presented and addressed the noise impacts associated with the proposed development.

It is recommended that these items are addressed to reduce the level of uncertainty, increase the accuracy of the assessment and to satisfy the requirements of the EIS Guidelines.

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1 Scope

1.1 Summary of approach

This scope of this report is to provide an unbiased peer review of all work presented as part of the draft

Western Sydney Airport Environmental Impact Statement (EIS) in relation to ground-based noise.

The draft Western Sydney Airport EIS was prepared to provide an assessment of environmental impacts

associated with the development of an international airport near Badgerys Creek in Western Sydney, NSW.

The EIS contains an assessment of noise impacts in two components; noise impacts from air-based activities

such as aircraft in flight, landing and take-off; and from ground-based activities such as aircraft taxiing and

ground based engine run-up. This review is concerned with ground-based activities only.

The Guidelines for the Content of a Draft Environmental Impact Statement – Western Sydney Airport (EIS

Guidelines) (Commonwealth Government, 2015) were released to provide a framework for the preparation of

the EIS.

The current status of the approvals process for the airport is presented in Figure 1-1. It is recommended that

the findings of this review are considered and incorporated into the final EIS prepared in the next phase of the

approvals process.

Figure 1-1 - Development approval process

This review has identified areas of uncertainty in the assessment provided in the EIS and has identified what

further assessments or detail is reasonably considered to be required to reduce these uncertainties and satisfy

the requirements of the EIS Guidelines.

Specifically this review:

■ Evaluates whether the study meet the requirements of the EIS Guidelines

■ Evaluates whether the conclusions reached in the studies are valid


■ Evaluates whether the underlying assumptions are plausible

■ Reviews the mitigation and management measures proposed

■ Evaluates the level of uncertainty over impacts and the environmental risks

■ Provides a summary of the key impacts and opportunities associated with the project in relation to aircraft noise as part of the noise and vibration study

■ Discusses the approach to assessment of long term development.

A document review is provided in Appendix A of this report which provides comment and recommendations for specific areas items in the EIS.

In order to identify the scale of significance for items identified as part of the review, the significance ratings in Table 1-1 have been adopted.

Table 1-1 - Significance scale

Significance Consequence

High Likely to result in significantly different outcomes

Medium Potential to change outcomes significantly

Low Unlikely to result in significantly different outcomes

Noted for information Unlikely to change outcomes, noted for information

1.2 Limitations

Noise modelling has not been conducted as part of this review as modelling files were not available for review. Therefore it is not possible to verify the validity of noise contour plots presented in the EIS. However, the review was conducted based on a visual inspection of the plots.

The review also relies on the source noise data included in the EIS. As the review is a desktop exercise it was not possible to undertake independent source noise measurements to verify the noise levels stated in the EIS for taxiing and engine ground running.

1.3 Components of the EIS reviewed

The EIS is divided into four volumes. For each volume the sections relevant to this review have been identified in Table 1-2.

Table 1-2 – EIS sections relevant to ground-based noise

EIS PART Section Title Page reference

Volume 1 — Project Background

N/A Executive Summary p30 – 33, p49 - 52

Part B Airport Plan p125 - 256

Volume 2 — Stage 1 Development — EIS for Stage 1 development (single runway facility in 2030)

Part D 9. Approach to impact assessment p3 - 18

Part D 11. Noise (ground operations, construction,

road and rail) p75 - 100

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EIS PART Section Title Page reference

27. Cumulative impact assessment p561 - 574

Part E 28. Environmental management framework p577 - 620

Part F 29. Conclusion p623 – 634

Volume 3 — Long Term Development — Strategic assessment of the long-term development (dual runway facility by 2063)

Part G

Approach to impact assessment p3 - 10

Assessment of Long Term Impact - Noise p11 - 72

Part H Conclusion and recommendations p193 – 200

Volume 4 — EIS Technical Reports

Appendix E E2 Airport ground-based noise and

vibration Separate report

1.4 Policy and guidance

The following documents, standards and guidance have been used to inform the EIS review process:

■ Airports (Environment Protection) Regulations 1997 (to be ceased by 1 April 2019)

■ Airports Act 1996

■ AS 2021: 2015 Acoustics – Aircraft Noise Intrusion – Building Siting and Construction

■ Assessing vibration: a technical guideline (Department of Environment and Conservation, 2006)

■ Australian Government Department of Sustainability, Environment, Water, Population and Communities – Actions on, or impacting upon, Commonwealth land, and actions by Commonwealth agencies – Significant impact guidelines 1.2 – Environment Protection and Biodiversity Conservation Act 1999

■ EIS Guidelines – Australian Government Department of the Environment (Commonwealth Government, 2015)

■ German Standard DIN 4150-3 Structural Vibration: Effects of Vibration on Structures.

■ NSW Industrial Noise Policy (Environmental Protection Authority, 2000)

■ NSW Interim Construction Noise Guideline (Department of Environment and Climate Change, 2009)

■ NSW Road Noise Policy (Department of Environment, Climate Change and Water, 2013)


2 Detailed findings - 1st stage airport

2.1 Summary

2.1.1 EIS Guidelines

A number of aspects were identified that did not satisfy the requirements of the EIS Guidelines.

■ The assessment did not present sufficient evidence to support the noise levels used in the predictions. Changes to the noise source levels could potentially lead to significantly different outcomes.

■ The identification of the type and magnitude of impact, both pre-mitigation and post-mitigation was not presented in the assessment.

■ The effectiveness of identified noise mitigation measures is not able to be identified.

■ The cumulative assessment does not consider the potential for noise impacts from the simultaneous operation of activities on the ground at the airport including ground based run ups and taxiing.

■ The cumulative assessment does not include consideration of the operation of the M12 motorway and The Northern Road realignment which provide access to the airport and are likely to introduce an additional significant noise sources into the area.

2.1.2 Assumptions

■ It has been assumed that Auxiliary Power Units (APU) would not be used at the airport. However, the type of ground power to be employed instead is not clearly defined. Ground power units (GPU) have the potential to cause additional noise impacts and the inclusion of either APU or GPU usage at the airport could adversely affect the outcome of the assessment.

■ There is insufficient information regarding assumed noise source levels used in the assessment, particularly in relation to noise from taxiing aircraft.

■ A single rating background level has been assumed for all receptors, rather than several location-specific values. This generalisation has underestimated the magnitude of noise impacts at receptors close to the airport that are currently exposed to low levels of environmental noise.

■ The assumption that construction traffic will primarily travel on Elizabeth Drive does not include an assessment of roads that connect to Elizabeth Drive being used by construction vehicles.

2.1.3 Conclusions

■ No consideration has been given to the cumulative noise impact from all ground noise sources at the nearest noise sensitive receptors both with and without mitigation measures. Additional assessment should also be undertaken for other ground noise sources, such as the compass calibration pad.

■ The conclusions reported in the body of the EIS regarding operational traffic noise are misleading as they do not state that development of a new motorway or substantial realignment of an arterial road to accommodate the airport were excluded from the assessment.

2.1.4 Mitigation and management measures proposed

■ It is recommended that the mitigation measures identified in the assessment, including the restriction of APUs and the limitation of engine ground run-ups during the night, should be formalised as part of the project approval.

■ The assessment does not provide sufficient evidence that all reasonable and feasible mitigation measures have been considered to reduce noise impacts from taxiing and ground run-ups.

11 | 44


2.1.5 Uncertainty of impacts and environmental risks

■ There are noise sensitive receptors closer to the airport than those selected for noise monitoring, leaving uncertainty over the current noise environment for the potentially most affected noise sensitive receptors.

■ The level of impact at the nearest sensitive receivers in Luddenham is not appropriately defined in the EIS and represents a potential risk to the validity of the assessments.

2.2 Detailed findings

2.2.1 Introduction

Appendix E2 – Airport ground-based noise and vibration is the primary document under review, as this

appendix forms the technical basis for all other ground noise related documents, including the EIS chapters.

2.2.2 Scope

The scope of the ground noise assessment is limited to aircraft taxiing noise, engine ground run-ups,

development generated road traffic noise and construction phase noise and vibration.

The noise impact of auxiliary power units (APUs) has been excluded, on the assumption that ground power and

preconditioned air will be provided at all gates, negating the need to use APUs. The use of APUs is not

discussed in the Airport Plan. Therefore there is a potential risk that APUs could be used in future, which could

change the result of the noise assessment.

An assessment of the noise impact of APU usage should be undertaken, if they could potentially be routinely

used.

There is a reference within the ground noise assessment to the use of reverse thrust at night-time, however it is

assumed that reverse thrust has been included in the aircraft noise assessment.

2.2.3 Baseline noise survey

From a review of available aerial mapping, there are closer noise sensitive receptors in the area than those

selected for noise monitoring, leaving uncertainty over the noise impacts on the most affected noise sensitive

receptors, particularly for properties in Luddenham to the north west of the Site. Figure 2-1 shows the adopted

noise monitoring locations that are closest to the Site boundary. Figure 2-2 shows that there are many noise

sensitive receptors much nearer to the Site boundary (marked in grey). Further consideration should therefore

be given to quantifying the existing noise environment for properties closest to the airport.


Figure 2-1 – Noise monitoring locations which are closest to the Site boundary

Figure 2-2 – Nearest noise sensitive residential receptors to the Site boundary (marked as light grey points)

There is insufficient detail provided to accurately determine the specific noise monitoring locations, whether

noise measurements were taken in free-field conditions, or at what height above ground microphones were

positioned at. It is not possible to determine whether microphones had direct line of sight to dominant noise

27 Dwyer Road

35 Ramsey Road

114 Mount Vernon Road

Western Sydney Airport – Ground Noise

13 | 44

sources such as main roads, or whether they were placed in backyards. There is a risk that existing noise

levels have been overestimated if they have not been placed on quietest facades of residential receptors. The

existing noise levels have been used to determine assessment criteria, so this information could potentially

affect the conclusions of the assessment. Therefore the precise measurement locations should be defined.

Figure 11-2 (reproduced below in Figure 2-3) depicts the noise sensitive receptors surrounding the airport site.

It identifies the location of nearby non-residential noise sensitive receptors in the area clearly, however the

location of residential receptors is indicated by very small points in light grey, which are difficult to observe and

could be considered misleading. It is recommended that Figure 11-2 is updated to show more clearly the

location of residential receptors.


Figure 2-3 - Sensitive receivers surrounding the airport site (reproduced from Western Sydney Airport draft EIS)

15 | 44

2.2.4 Criteria

Ground based operations noise

There is insufficient evidence that the intrusiveness criterion is more stringent than the amenity criterion for all

assessed locations. Based on the rural nature of the surrounding area, Table 2.1 of the NSW Industrial Noise

Policy 2000 (INP) (presented in Table 2-1 of this report) recommends a noise level of 40 dB LAeq at night as

“acceptable”. This is lower than some tabulated night-time values in Table 3-1 of Appendix E2 (albeit they are

LAeq,15min, corrected). The incorrect criterion selection could potentially underestimate the extent of the noise

impacts, therefore further evidence should be provided to demonstrate that the intrusiveness criterion is the

more stringent at all locations.

Furthermore, the contribution from existing industrial noise sources was not quantified in the assessment,

therefore there is insufficient evidence presented in the report

The approach of selecting one noise criterion undermines the results of the noise monitoring at multiple

locations. Noise criteria at five of the ten locations are lower than 40 dBA, and as low as 35 dBA, which is 5 dB

lower than the adopted criterion. As a result, noise impacts at some locations are considered to have been

incorrectly identified, and should be reassessed for each measurement location using the criterion specific to

that assessment location.

Table 3-2 of Appendix E2 sets out noise criteria for non-residential receivers based on recommended maximum

LAeq levels. However Section 2.2 of the INP states that, in all cases, it is expected that all feasible and

reasonable mitigation measures would be applied before the recommended maximum noise levels are

referenced. Therefore the “acceptable” noise levels stated in Table 2.1 of the INP should be used in the first

instance, rather than “Recommended Maximum”. The criteria adopted would therefore be 5 dB lower than that

used in the assessment, which could potentially alter the assessment outcome.

No assessment of low frequency noise or other modifying factors as defined in Section 4 of the INP has been

conducted. The assessment should be revised to include consideration of these aspects.


Table 2-1 – INP Amenity criteria (reproduced from Table 2.1 of the INP)

Construction noise and vibration

It is unclear whether the adopted construction noise criteria are based on the NSW Interim Construction Noise

Guideline (ICNG) or the Airports (Environment Protection) Regulations 1997. Usual hours of construction are

proposed from 6.00 am, which is classed as night-time. Therefore, it is important that the appropriate criterion is

used for night-time work, which will be included in standard hours of construction. It is recommended that

17 | 44

clarification is provided for the appropriate criteria set to be used for the assessment during daytime and night-

time periods.

Table 2 of the ICNG states that strong justification would typically be required for works outside of the

recommended standard hours. No justification has been provided in the assessment.

The construction noise assessment identifies that, for some receptors, the noise management level (NML)

should be 39 dBA, however 45 dBA (weekday) and 40 dBA (weekend and early morning works) have been

adopted as the criteria set. This potentially underestimates the noise impacts from construction by up to 6 dB.

Construction noise should be reassessed based on the different measurement locations adopted in the

assessment, in order to more accurately quantify the potential noise impacts.

Road traffic noise

The Road Noise Policy (RNP) and RNP application notes provide specific criteria for the assessment of land

uses affected by traffic generating developments on existing roads. Whilst the report does provide an

assessment of impacts consistent with the RNP, the appropriate section of the RNP and RNP application notes

should be referenced in the report.

2.2.5 Noise modelling

Assumptions

It has been assumed that there will only be one high power run up, which would occur for less than 5 minutes in

any night. INP Section 4.2 states that the acceptable noise level may be increased by 5 dB to account for

unusual and one-off events, but does not apply to regular high-noise levels that occur more frequently than

once per day. Should there be more than one high power run-up in one night, it would be inappropriate to apply

this correction. Clarification is required to determine the likelihood of high power ground run-ups in a given

night-time period.

The assumed location for ground run-ups is defined in Figure 3-1 of Appendix E2 (presented in Figure 2-4

below), however the indicative building location near the location is not finalised nor is fixed within the

application. Figure 3-2 of Appendix E2 (presented in Figure 2-5 below) shows that communities to the west and

north west of the Site benefit from the screening afforded by this building. Noise impacts could significantly

change if the buildings or run-up area change location. It is therefore considered appropriate to assess a

scenario where the building does not provide any acoustic benefit, to take into account that final locations are

not fixed and may change.


Figure 2-4 - Ground based operational noise source locations, 2030 (reproduced from EIS Appendix E2 Figure 3-1)

Figure 2-5 - Worst case LAeq,15min engine ground running noise contours, 2030 (reproduced from EIS Appendix E2 Figure 3-2)

19 | 44

Source noise data

Chapter 9 Table 9-2 of the EIS presents EIS Guideline requirements and indicates where in the EIS they are

addressed. In Table 9-2 Section 11 – Information sources it states that for information given in the EIS, the EIS

must state (amongst other points) the source of the information, how recent the information is, and how reliable

the information is. This requirement has not be fulfilled in the EIS as this information is not presented for the

noise source levels in the ground based noise assessment.

A sound power level of 151 dBA has been assumed for aircraft engine ground running, based on

measurements of aircraft taking off. There is no indication of which aircraft this refers to, or the range of typical

levels that might be expected. It is assumed that this level is an A weighted Sound Power Level (LWA), however

it is not explicitly stated. More information should be provided regarding the adopted source noise level and the

range of values expected from engine run-ups, given the anticipated fleet of aircraft for the airport.

A sound power level of 138 dBA has been assumed for taxiing aircraft. This is stated as the highest level

measured, based on measurements of a B777, B747, B737, B717 and A330 aircraft. It is assumed that the 747

taxi noise has been used for the purposes of the noise modelling exercise. In addition, the directionality of the

source has not been stated. As aircraft engines are directional sources, there is potential for an

underestimation of impacts from a directional source with the same sound power level as an omni-directional

source. As a result, it is unclear how this sound power level has been calculated.

Taxiing aircraft is in essence a moving point source. Depending on how the source has been modelled, this

may not be the appropriate sound power level to use (e.g. series of point sources, line source with a total sound

power, line source with a sound power per unit length). It is unclear whether taxiing was under two engine

conditions, one engine conditions or engine off taxiing (EOT). Clarification is required on the method used to

determine the sound power level for the line source, and the measurements that were undertaken in support of

this.

2.2.6 Assessment

General

The requirements of Section 5 “Relevant Impacts” and Section 7 “Residual impacts and offsets” in Table 9-2

have not been met within Chapter 11, and this chapter should be updated to include clear statements on

whether impacts are short term, long term, direct, indirect, unknown, predictable or irreversible, and a clear

indication of the significance of the impacts, pre and post mitigation. This should include the reasons why

avoidance or mitigation of impacts may not reasonably be achieved, where necessary.

A magnitude scale for impact significance should be set out at the beginning of the chapter and used for pre-

mitigation and post mitigation assessments so that it can be seen what the residual noise impacts are predicted

to be.


The assessment year for Stage 1 is 2030, which is only five years after anticipated opening. Given that

passengers and air movements are expected to steadily increase to 2050, when the single runway will be at full

capacity, it could be considered more appropriate to take 2050 (i.e. 25 years after opening) as the assessment

year so that realistic longer term impacts can be taken into account. Given that there is more certainty over this

than a two runway scenario, it is important that the single runway noise impacts are fully explored.

Table 3-4 of Appendix E2 (reproduced in Table 2-2) shows the population affected above the adopted criteria

for engine ground running and taxiing. The table may be subject to change when the issues identified in this

review are addressed. It is recommended that it is stated how many receptors will be exposed to 5 dB above


criterion, 10 dB above criterion etc. as there is currently no indication of the magnitude of exceedance that will

be experienced by individual receptors. At this stage, it is likely that the population numbers will increase.

Table 2-2 - Predicted residential noise impact of ground-based operational noise under worst-case conditions (reproduced from appendix E2 Table 3-4)

Similarly, Table 3-5 of Appendix E2 (shown in Table 2-3) shows other receivers and land uses affected above

the adopted criteria for engine ground noise and taxiing. There may also be implications to this table as a result

of the above issues. It is recommended that the actual noise levels anticipated at these buildings/areas are

presented so that the magnitude of the exceedance can be understood.

Table 2-3 - Predicted noise impact of ground-based operational noise on other receiver types under worst-case conditions (reproduced from Appendix E2 Table 3-5)

Road traffic noise

The construction road traffic noise assessment only includes an assessment of impacts from vehicles

accessing the site on Elizabeth Drive. No assessment or comment is provided for other stages of construction

where there are additional entrances to the site, nor for roads which connect to Elizabeth Drive, which may

carry construction traffic.

The road traffic noise assessment for the operational airport does not include the assessment of the planned

M12 motorway or The Northern Road realignment which are being developed to accommodate the airport. The

impacts of these projects has been excluded from the assessment as these are to be developed and approved

by other authorities and proponents. However, the EIS does not state the limitations of the assessment, which

does not include these major road projects, as presented in Appendix E2.

The assessment of road traffic noise only includes assessment of one year (2030). It does not provide sufficient

justification for the omission of other operating years for example up to 2050. It is considered likely that traffic

21 | 44

on the assessed roads would increase as a result of the second stage of development and no comment has

been made on this.

2.2.7 Mitigation

General

Section 6 of the EIS Guidelines, “Avoidance and mitigation measures”, states that the EIS must include an

assessment of the expected or predicted effectiveness of mitigation measures. The draft EIS does present

analysis to satisfy this requirement and it is recommended that an assessment of the expected or predicted

effectiveness of each mitigation measure identified is provided.


The restriction on the amount of high power running at night time is stated to substantially reduce the impact of

ground running noise. As this assumption has been included the noise predictions, night-time engine ground

run-up should be conditioned appropriately as part of the project approval.

Engine run-up noise mitigation measures are identified, including the construction of buildings, mounds or

barriers near the run-up area to provide greater acoustic screening, and the possibility of relocating the run up

area further to the south-east to reduce the noise impact on Luddenham. The quantifiable benefits to the

closest noise sensitive receptors from the adoption of such measures should be defined, in terms of resultant

noise levels and the residual exceedance of the criteria. The use of such measures should be included in the

project approval for appropriate periods.

The assessment states that there is “little that could be done to reduce noise levels emanating from the airport

as a result of taxiing”. However, there are a number of potential mitigation measures that could be considered,

including single engine taxiing, engine off taxiing (EOT) and the installation of acoustic barriers at effective

locations. It is therefore recommended that consideration should be given to these mitigation measures in a

revised assessment. In addition, the unmitigated noise impact from taxiing and the residual noise impact

following potential mitigation measures should be presented. The measures identified to be reasonable and

feasible should be included in the project approval.

The assessment has assumed that APUs will not be used, and that instead ground power and pre-conditioned

air will be available at all gates. However, ground power could be supplied either by fixed electrical ground

power (FEGP), or by Ground Power Units (GPUs). GPUs could have the potential to cause noise impacts and

should be assessed accordingly. An approval condition should be included that restricts the use of APUs, and

the type of ground power to be employed on site.

The use of ground power and pre-conditioned air are not included in Table 11-13 of Chapter 11, which sets out

the mitigation and management measures, nor is any mention of the restriction over APU usage.

Construction noise and vibration

The report identifies the need for a Construction Noise & Vibration Management Plan. This should be

conditioned appropriately as part of a project approval.

2.2.8 Cumulative assessment

Cumulative noise impact from engine run-ups and taxiing have not been considered, and no assessment has

been included for airside service vehicles, sirens, noise from fixed plant associated with the airport buildings or

use of the compass calibration pad. As a minimum, consideration should be given to the cumulative noise

impact from all ground noise sources at nearest noise sensitive receptors with and without mitigation measures.

The cumulative noise assessment is not consistent with the requirements of the EIS Guidelines as it does not

include an assessment of cumulative noise impacts associated with the operation of the M12 motorway or


realignment of The Northern Road, which are being developed to accommodate the airport. These planned

road projects have the potential to significantly increase noise levels in the area surrounding the airport and

should therefore be considered as part of a cumulative assessment.

2.2.9 Conclusions

Chapter 21 Table 29-1 provides a summary of the key environmental impacts. The “Noise – ground operations,

construction and road traffic” section of the table does not provide an indication of the magnitude of significance

of the noise sources stated, and whether mitigation measures are included. There is also no evaluation of the

acceptability of the noise impacts. The table should be updated to include this detail.

The conclusions of the draft EIS that there are no significant operational traffic noise impacts is misleading, as it

does not acknowledge the limitations of the assessment, which excludes the development of the M12

motorway and substantial realignment of The Northern Road to accommodate the airport. The statements

relating to operational traffic noise should be updated to acknowledge the limitations of the road traffic noise

assessment.

23 | 44

3 Detailed findings - long term development

3.1 Summary

The assessment is considered to contain an appropriate level of detail for the long term development as the potential noise impacts are predicted for a considerable time in the future (into 2063). It is acknowledged that the noise environment may change over time. The identified issues are summarised as follows:

■ The comments raised in this review for the 1st stage airport assessment should be addressed and applied to the long term development assessment. Where this occurs, the current framework for further assessment of the long term development is considered appropriate.

■ The draft EIS does not include ground-based noise in the summary or conclusion for the long term development. It is recommended that the outcomes of the revised long-term development ground-based noise assessment are included in these sections so that all impacts are clearly presented.

■ The assessment does provide comment on the potential noise impacts from the long-term development of the airport. The trip generation of the fully developed airport is predicted to be over 300,000 vehicles per day and no comment has been made on potential noise impacts on the surrounding existing road network, including the M7 and The Northern Road.

3.2 Detailed findings

3.2.1 Modelling

Engine ground run-up noise in 2063 has been modelled at the location indicated in Figure 3-4 of Appendix E2,

shown below in Figure 3-1. Figure 3-5 of Appendix E2 shows the noise propagation from this source but does

not have the same level of acoustic screening afforded by nearby buildings as that shown in Figure 3-2 of

Appendix E2, which is the corresponding noise contour plot for the single runway scenario. These two figures

are compared in Figure 3-2 below). There is therefore uncertainty regarding the level of screening from

buildings.

Clarification is also required regarding the assumption that, in the event of a two runway airport, there would

continue to only be one ground run-up area.


Figure 3-1 - Ground-based operational noise source locations, 2063 (reproduced from Appendix E2 Figure 3-4)

Figure 3-2 - Comparison between worst-case LAeq,15min engine ground running noise contours for 2030 (single runway, left) and 2063 (two runway, right)

Figure 3-4 of Appendix E2 does not accurately represent Figure 5-3 of the draft EIS Volume 1 (p143) document

which shows the indicative airport site layout – long term development. The two figures are compared in Figure

3-3 below. In particular, there are additional areas within that layout where aircraft would be taxiing that have

not been included in the noise model. The model only accounts for the usage of 63 out of 95 aircraft gates. It is

recommended that the model is updated to include the additional areas where aircraft will be taxiing. It is

anticipated that there will be an increase of approximately 1 dB in including these additional areas.

25 | 44

Figure 3-3 - Comparison between modelled noise sources in 2063 (Appendix E2 Figure 3-4, top image) and indicative airport site layout in 2063 (Volume 1 Chapter 5 Figure 5-3, bottom image)


3.2.2 Assessment

The 2063 aircraft taxiing noise contours shown in Volume 3 Chapter 31 Figure 31-39 show the increased

number of aircraft movements and extend further south as a result of the commissioning of the second runway.

The aircraft noise section (Volume 3 Chapter 31, Sections 31.2 to 31.4, Tables 31-7 to 31-9) has identified the

population numbers affected by aircraft noise, however this information is not presented for ground noise.

There is no indication of the level of exceedance for nearest noise sensitive receptors in order to determine the

magnitude of the impact. It is recommended that population number affected by ground noise is included, in 5

dB bands, in order to determine the magnitude of the potential noise impact.

The assessment does not comment on the potential road traffic noise impacts as a result of the long term

development. The traffic and transport assessment (draft EIS Appendix J) includes predictions that indicate

more than 300,000 additional trips would be generated by the development of the airport by 2063. This volume

of traffic is more than the typical volumes currently carried by some motorways in Sydney. As a result it is

recommended that comment is made to identify the potentially affected roads and noise impacts as a result of

such traffic generation.

3.2.3 Conclusions

There is no reference to ground noise in the summary of findings or the Conclusion and Recommendation

chapter (Chapter 40) of Volume 3. Ground noise impacts may therefore not be considered by decision makers.

A summary of the ground noise impact assessment should be included in this chapter.

27 | 44

4 Key impacts and opportunities

Below is a summary of the key impacts and opportunities that have been identified as a result of the review.

■ There is insufficient detail surrounding the selection of source noise data. Changes to the source noise data could potentially lead to a significantly different outcome.

■ The draft EIS does not satisfy the EIS Guideline requirements to identify the type and magnitude of impact, both pre-mitigation and post-mitigation.

■ The exclusion of Auxiliary Power Unit (APU) usage at the airport and uncertainty surrounding the method of alternative ground power could potentially adversely affect the outcome of the assessment.

■ A single noise level has been used for existing noise levels at all receptors, rather than several location-specific values. This generalisation has underestimated the magnitude of noise impacts at receptors close to the airport that are currently exposed to low levels of environmental noise.

■ No consideration has been given to the cumulative noise impact from all ground noise sources at nearest noise sensitive receptors with and without mitigation measures. Further consideration should also be given to noise from other ground noise sources, such as the compass calibration pad.

■ Several mitigation measures have been put forward, including the restriction of APUs and the limitation of engine ground run-ups during the night. These measures should be included as part of any approval conditions.

■ Sufficient analysis of feasible and reasonable mitigation measures to reduce taxiing noise has not been included. Several mitigation options exists which are not discussed in the assessment. It is recommended that further analysis is conducted for these measures.


■ Nearest noise sensitive receptors such as residences in Luddenham have not been included in the baseline noise monitoring. It is recommended further noise monitoring is undertaken in this area.

■ The findings of the long term development ground noise impact assessment are not included in the draft EIS chapter summary or the conclusion chapter. A summary of the ground noise impact assessment should be included in these areas.

■ The potential cumulative impact of the M12 motorway and realignment of the Northern Road which are being developed to accommodate the airport should be considered in the assessment.

■ No comment is made on the long term developments potential noise impacts from significant traffic generation from the airport. It is recommended that this is included in the assessment.

The above issues currently indicate a high level of uncertainty over the accuracy and extent of the noise impact from ground noise currently. In particular, from ground noise related operations at the airport. It is recommended that each point above be considered and addressed in subsequent assessment of ground noise for the airport.


5 Qualifications of the study team

5.1 Project manager

Alex Campbell, Asia-Pacific Acoustics Manager

MEng, MAAS, MIOA, C.Eng

12 Years’ Experience

Alex leads the WSP | Parsons Brinckerhoff acoustics team in the Asia-Pacific region. He has over 12 years industry experience, the last 9 years of which have been with WSP Acoustics - who are one of the world’s largest globally connected acoustic specialist teams employing 150 engineers worldwide.

He has seen the successful completion of projects in a wide range of sectors, and has managed and been technically involved with projects including Review of Environmental Factors (REF) and Environmental Impact Statement (EIS) Noise & Vibration assessments throughout Australia. In addition to this, Alex has significant experience in delivering major international projects on-time and on-budget for both government and private sector clients.

5.2 Supporting technical team

Mike Barrett, Principal Acoustic Consultant

BSc(hons), MIOA


Mike has worked on projects associated with many of the UK’s largest airports, including Heathrow, Gatwick, Stansted, Manchester, London City and Luton Airports – many of which have been in the capacity of peer reviewer.

Mike is a Principal Acoustic Consultant for WSP | Parsons Brinckerhoff, and has 10 years’ experience in the modelling, monitoring and assessment of noise and vibration. He has been involved with a wide range of environmental, architectural and building services projects, and regularly provides specialist advice to developers, architects, industry and local authorities.

During his time in consultancy experience has been gained across a number of different sectors including aviation, surface transport, residential, industrial, commercial, leisure and retail, and he presently sits on the Institute of Acoustics UK North West Branch Committee.

Adrian White, Associate Acoustic Consultant

BSc, MAAS


Adrian has worked on major EIS projects throughout Australia. He has over eight years of experience working as a professional and acoustic consultant in Australia with internationally recognised noise and vibration consultancies. Adrian specialises in acoustics with niche expertise in a variety of areas such as environmental and industrial acoustics, architectural acoustics and transportation noise and vibration.

Chris Marsh, Senior Acoustic Consultant

MEng, MAAS, AMIMechE


Chris is a senior acoustics engineer at WSP | Parsons Brinckerhoff experienced in environmental acoustics and monitoring projects. He has over five years’ experience in the assessment, monitoring and management of environmental noise and has been involved in a number of major projects across transportation, industrial and resource sectors.

Appendix A Document review

Section / Paragraph Reference

Text Reference / Figure Description Comment Recommendation Significance of

Issue

Appendix E2 – Airport ground-based noise and vibration

1.3 /

p5 para 1

“The use of auxiliary power units (APUs) on aircraft has not been assessed because it is assumed that power and pre-conditioned air would generally be supplied to aircraft at the terminal gates.”

There is no mention of the use of APUs in the Airport Plan. The potential effect of using APUs has not been covered, nor has it been expressly stated that they would not be used.

Clarification should be sought as to whether APUs will be used.

Assessment of the noise impact of APU usage, should such usage be an option.

Medium

2 /

p6

A description of the baseline noise survey that has informed the setting of noise limits

There is insufficient detail contained within the section to determine the specific noise monitoring locations.

For example, it is unclear as to whether noise measurements were taken in free-field conditions, and what height above ground the microphone was positioned at.

Crucially, it does not include a description of the exact measurement location to be able to determine whether microphones had direct line of sight to dominant noise sources such as main roads, or whether they were placed in rear gardens.

There is a risk that existing noise levels have been overestimated if they have not been placed on quietest facades of residential receptors.

Clarification on exact noise measurement locations.

Low

2 /

p6 para 2

“The locations were also chosen to represent potentially-affected development in the surrounding area.”

From a review of available aerial mapping, it is evident that there are closer noise sensitive receptors in the area than those selected for noise monitoring.

There is a concern that the potential impacts on the most affected noise sensitive receptors have not been accurately quantified.

Properties in Luddenham to the north west of the Site are particularly close yet there has been no noise monitoring undertaken in this area

Further consideration should be given to quantifying the existing noise environment for properties closest to the airport, particularly Luddenham.

Low




Issue

3.1 /

p9, para 5,

Table 3-1

“In the area surrounding the airport, the intrusiveness criterion is the more stringent at all locations.”

There is no evidence base for the conclusion that is drawn regarding the appropriate criteria set to be used. This could potentially underplay the extent of the noise impacts.

Based on the rural nature of the surrounding area, Table 2.1 of the INP recommends a noise level of 40 dB LAeq at night as “acceptable”. It is clear that this is lower than some tabulated night-time values in Table 3-1, albeit they are LAeq,15min (corrected).

Evidence to demonstrate that the intrusiveness criterion is the more stringent at all locations.

Low

3.1 /

p10, para 2, Table 3-1

“So that the noise contours included below in this report can be readily interpreted, it is preferable to adopt one criterion for all residences an overall noise criterion of 40 dBA can be taken as generally appropriate for residential locations at night.”

The approach of selecting one criterion undermines the results of the noise monitoring at multiple locations. It is clear that noise criteria at five of the ten locations are lower than 40 dBA, and are as low as 35 dBA, which is 5 dB lower than the adopted criterion.

Noise impacts at certain locations have been incorrectly identified.

Request reassessment for each measurement location using the appropriate criterion for that receptor, as set out in Table 3-1

Medium

3.1 /

p10, para 2

“By the time the proposed airport becomes operational, background noise levels in the general area are expected to have increased as a result of increased road traffic and associated development in the surrounding area. This would particularly be so for the lower background noise levels and would in turn raise the value of the appropriate noise criteria for the assessment of airport operational noise.”

The argument made in the paragraph is in reference to selecting an overall noise criterion of 40 dBA, which would be up to 5 dB higher than the locations-specific criteria set out in Table 3-1. However, an increase of 5 dB would be, in simple terms, equivalent to more than three times the amount of sound energy incident at the measurement location.

Therefore, for road traffic to have this impact, there would need to be more than three times the amount of traffic that is currently on the road network, assuming no changes to the current road network.

None, comment for information only. Noted for

information

31 | 44



Issue

3.1 /

p11, Table 3-2

Table setting out “noise criteria for other receiver types”, referring to those other than residential receivers.

Values contained within the table are recommended maximum LAeq Noise Criteria.

Section 2.2 of the INP states the following:

“To limit continuing increases in noise levels, the maximum ambient noise level within an area from industrial noise sources should not normally exceed the acceptable noise levels specified in Table 2.1. Meeting the acceptable noise levels in Table 2.1will protect against noise impacts such as speech interference, community annoyance and, to some extent, sleep disturbance. These levels represent current best practice for assessing industrial noise sources, based on research and a review of assessment practices used overseas and within Australia.

Table 2.1 also includes recommended maximum noise levels for different land uses. These recommended maximum values provide guidance on an upper limit to the level of noise from industry. In all cases it is expected that all feasible and reasonable mitigation measures would be applied before the recommended maximum noise levels are referenced.”

The “Acceptable” noise levels stated in Table 2.1 of the INP should be used in the first instance, rather than “Recommended Maximum”, which would in turn mean the criteria adopted would be 5 dB lower than used in the assessment.

Medium

3.2 /

p11, para 3

“For modelling purposes it has been assumed that high power run up would occur for less than 5 minutes in any night. Therefore, the night time residential criterion for this activity has been set using the industrial noise criterion as 5 dB over the general INP night time criterion for residential receivers; that is 45 dBA, in accordance with the INP duration adjustment.”

INP Section 4.2 states that the acceptable noise level may be increased by the adjustment shown in Table 4.2 of the INP, and that the adjustment is designed to account for unusual and one-off events, and does not apply to regular high-noise levels that occur more frequently than once per day.

Should there be more than one high power run-up in one night, it would be inappropriate to apply this correction, and given that this is a realistic scenario, there is a concern that the criterion set is inappropriate.

Evidence to show the likelihood of high power ground run-ups in a given night-time period.

Reassessment, where appropriate, of impact of high power ground running.

High

3.2 /

p11, para 4

“Like other major airports in Australia, the proposed airport is expected to have restrictions in place on engine ground runs, including limitations on night time run up activity.”

Assumption on future controls. None, comment for information only.

Consideration to condition.

Noted for information




Issue

3.5.1 /

p13, para 2, Figure 3-1, Figure 3-2

“It has been assumed that aircraft ground runs would occur at the location shown in Figure 3-1.”

It is acknowledged that the assumed location for run-ups is defined in Figure 3-1, however there is a concern that, at this stage, the indicative building location near the position is not finalised nor is fixed within the planning application.

It is evident from Figure 3-2 that communities to the west and north west of the Site benefit from the screening afforded by this building.

Should the building or run-up area move, it is likely that it could significantly affect the resulting noise impact from the Site.

Given the indicative layout, and the level of assumed acoustic benefit provided, it is considered appropriate to assess a scenario where the building does not provide any acoustic benefit, to take into account that final locations are not fixed and may change.

High

3.5.1 /

p13, para 2,

On the subject of source noise levels for aircraft engine ground running “… a level of 151 dBA has been assumed, based on measurements of aircraft taking off.”

There is no indication of which aircraft this refers to, or the range of typical levels that might be expected.

It is assumed that this level is an effective A weighted Sound Power Level (LWA), however it is not explicitly stated.

It would be expected that, given the potentially critical nature of the noise impact in the progression of the scheme, it would be appropriate to provide more information regarding the adopted source noise level.

More information is required regarding the range of values expected from engine run-ups given the anticipated fleet of aircraft for the airport, and more information regarding which aircraft the 151 dBA refers to.

Medium

3.5.2 /

p13, para 5

“A sound power level (noise level at source) for each aircraft of 138 dBA has been assumed. This is the highest level measured for aircraft taxiing, based on measurements of a B777, B747, B737, B717 and A330 aircraft.”

Typically, turboprops emit higher noise levels than jet aircraft whilst taxiing. It is anticipated that there will be a very low number of turboprops in service at the airport.

It is unclear how this sound power level has been calculated. Taxiing is in essence a moving point source.

Depending on how the source has been modelled, this may not be the appropriate sound power level to use.

It is also unclear whether measured taxiing was under two engine conditions, one engine conditions or engine off taxiing (EOT).

Confirmation of the method used to determine the sound power level for the line source that has been used, and confirmation that measurements were undertaken to determine this. It would be useful to have the data presented in a table within the report.

Medium

33 | 44



Issue

3.6 /

p15, Table 3-4

Table 3-4 shows population affected above criterion.

There may be implications to this table as a result of the above issues.

It would also be helpful to understand how many receptors will be exposed to 5 dB above criterion, 10 dB above criterion etc.

Update table based on the outcome of the above recommendations.

It is likely that the population numbers will increase.

Provide number of people exposed to 5 dB above criterion, 10 dB above criterion etc.


3.6 /

p16, Table 3-5

Table 3-5 shows other buildings and land uses affected above criterion.

There may be implications to this table as a result of the above issues.

It would be helpful if the actual noise levels anticipated at these buildings/areas are presented, given the small number of them, so that the magnitude of the exceedance can be understood.

Update table based on the outcome of the above recommendations.

It is likely that the population numbers will increase.

Provide noise levels anticipated at each receptor.


3.6 /

p16, para 2

The text refers to the use of reverse thrust at night.

It is assumed that reverse thrust at night has been included in the aircraft noise assessment.

Consider removing reference Noted for

information

3.7 /

p17, para 2, Figure 3-4, Figure 3-5

“Ground-based noise levels have been predicted for the longer term airport development using the same methods as for the initial airport development. The noise source locations are shown in Figure 3-4 and the resulting contours are shown in Figure 3-5 and Figure 3-6.”

The text infers that, even with two runways and a significant increase in aircraft movements as a result, there would still be only one engine run-up for less than 5 minutes in any 15 minute period.

This single point source of noise has been modelled as indicated in Figure 3-4, however Figure 3-5 (which shows the noise propagation) does not appear to have the same level of acoustic screening from nearby buildings as the similar situation in Figure 3-2, which suggests that either Figure 3-2 overestimates the level of acoustic screened afforded by buildings, or Figure 3-5 underestimates this.

Clarification that, in the event of a two runway airport, there would continue to only be one ground run-up area.

Confirmation that the acoustic screening from buildings has been correctly accounted for in both Figure 3-2 and Figure 3-5

Medium

3.7 /

Figure 3-4

The figure shows ground-based operational noise source locations in 2063

The figure does not accurately represent Figure 5-3 of the EIS Volume 1 (p143) document which shows the indicative airport site layout – long term development.

In particular, there are additional areas within that layout where aircraft would be taxiing that have not been included in the noise model. The model roughly only accounts for the usage of 63 out of 95 aircraft gates.

It is recommended that the model be updated to include the additional areas where aircraft will be taxiing.

Low




Issue

3.8 /

p19, para 3

“High power running at night time should be restricted to special circumstances where high power testing is required after maintenance activity prior to an aircraft taking off […] Restricting the amount of high power running at night time would substantially reduce the impact of ground running noise.”

The paragraph refers to mitigation measures, however this has already been factored in to the original noise assessment.

It is therefore important that this mitigation measure is carried through to operation.

Condition night-time engine ground run-up appropriately.


3.8 /

p19, para 3

“It may also be practical to construct buildings, mounds or barriers near the run-up area to provide greater noise shielding, particularly on the northern side to shield the closest area of Luddenham. It is possible that reductions of around 10 dBA could be achieved with mounds or buildings at least 10 m high, but moderate residual impacts would still occur under worst-case meteorological conditions. There may also be a benefit in relocating the run up area further to the south-east to reduce the noise impact on Luddenham, but practical operational issues would need to be considered for this.”

It is unclear within the report what the quantifiable benefits to the closest noise sensitive receptors would be from moving the run-up area and installing run-up pens or barriers, in terms of resultant noise levels and the residual exceedance of the established criteria.

It is unclear as to whether the impact during the day would be acceptable.

Given that moderate residual impacts are predicted with run-up pens, it is recommended that consideration be given to a more thorough assessment of the acoustic benefits of including such an area, and that its use should be conditioned during appropriate periods.

Confirmation of the level of impact during the day.


3.8 /

p19, para 4

“Aircraft taxiing noise would be relatively low in comparison to other noise associated with operation of the airport. There would be little that could be done to reduce noise levels emanating from the airport as a result of taxiing.”

The statements made do not appear to be accurate. On inspection of the noise contours, particularly for the long term scenario, noise from taxiing is on a similar scale to noise from engine run-ups.

There are a number of potential mitigation measures that could be considered, including single engine taxiing, engine off taxiing (EOT), the installation of acoustic barriers at effective locations

Consideration to the unmitigated noise impact from taxiing and the residual noise impact following possible mitigation measures, which could be conditioned.

High

3.8 /

p20, para 2

“The proposed use of ground power and pre-conditioned air for aircraft at the gates avoids the use of aircraft auxiliary power units and the associated noise.”

The assessment has assumed no use of auxiliary power units (APUs). The report assumes that ground power and pre-conditioned air will be available at all gates. However, ground power could be supplied either by fixed electrical ground power (FEGP), or by Ground Power Units (GPUs). Should the latter be used, it would be expected that they could have the potential to cause a noise impact and should be assessed accordingly.

Recommend that a condition is included that restricts the use of APUs.

Clarify the type of ground power to be used.

If GPUs are to be used, assess their noise impact.

Medium

35 | 44



Issue

3 /

General

There is no consideration given to the cumulative noise impact from engine run-ups and taxiing, and no assessment has been included for airside service vehicles, sirens, noise from fixed plant associated with the airport buildings or use of the compass calibration pad.

As a minimum, it would be expected that some consideration would be given to the cumulative noise impact from all ground noise sources at nearest noise sensitive receptors with and without mitigation measures.

Recommend a cumulative ground noise assessment is included, and further consideration be given to noise from other ground noise sources.

Medium

4.1.1 /

P21, para 4

Various construction noise criteria are discussed.

It is unclear as to whether the criteria is based on the NSW Interim Construction Noise Guideline (ICNG) or the Airports (Environment Protection) Regulations 1997.

Usual hours of construction are proposed from 6.00 am, which is classed as night-time. Therefore, it is particularly important that the appropriate criterion is used for night-time work as this will be the norm.

In addition where the ICNG is used, the guidelines states that strong justification should be provided for works that occur outside of standard hours.

Clarification of the appropriate criteria set to be used for this assessment for daytime and night-time.

Medium

4.1.1 /

P21, para 5

“Based on the daytime background noise levels shown in Table 2-1, the daytime residential NML would be between 39 dBA and 49 dBA for standard hours. For assessment of construction noise, a NML of 45 dBA may reasonably be adopted for all residential receivers, for week-day construction. Equally, for weekend works and early morning works, an NML of 40 dBA may be adopted.”

The report identifies that, for some receptors, the NML should be 39 dBA, however 45 dBA (weekday) and 40 dBA (weekend and early morning works) have been adopted as the criteria set.

This potentially underplays the noise impacts from construction by up to 6 dB.

Reassess based on the different measurement locations adopted in the assessment in order to more accurately quantify the potential noise impacts.

Low

4.4 /

P29, para 4

“It is proposed that these strategies be applied to areas of exceedance identified in the preceding section. The contractors responsible for the construction works should implement a Construction Noise & Vibration Management Plan. The Plan should provide for ongoing communication with potentially-affected residents and establish a complaint management and response system.”

The report identifies the need for a Construction Noise & Vibration Management Plan.

Recommend that this be included as a planning condition.





Issue

4.6 /

P31, para 1

“All construction traffic is expected to travel to the site via Elizabeth Drive.”

No assessment has been made for construction vehicles on roads accessing Elizabeth Drive for example The Northern Road, Luddenham Road, Mamre Road etc. No justification for excluding these roads is provided.

In addition, Section 6.2.4 of the EIS indicates that for site establishment works, additional site accesses would be utilised on roads other than Elizabeth Drive.

Additional assessment of construction vehicles accessing Elizabeth Drive and other site accesses should be included.

Medium

4.6 /

Table 4-7

Results table presents predicted increases in noise level for three sections of Elizabeth Drive.

The construction traffic assessment only considers three sections of Elizabeth Drive, whereas the Operational traffic assessment considers five sections which include additional sections: West of Badgerys Creek and West of Luddenham Road. No assessment has been provided for these sections in the construction traffic assessment

Justification should be provided for why there are inconsistencies between the operational and construction traffic assessment.

Medium

4.6 /

p31, para 3

Using the traffic noise criterion discussed in Section 5.2 below, it is concluded that this level of noise change resulting from the proposed construction works would not represent a perceptible noise increase.

As calculation details are not available for review, the results are not able to be verified. However, for the results presented in the report, this conclusion is considered acceptable.

None For information only

5 /

P32 -

The assessment acknowledges the future development of the M12 motorway, however does not specifically mention the planned realignment of The Northern Road to accommodate the airport.

The Northern Road realignment is acknowledged and considered in the report.

For information only

5 /

P32

“Future road works would be the subject of separate approval processes by the relevant authorities undertaking these actions and the assessment of these is not covered in this document. However, a preliminary assessment of the general impact of the expected change in road traffic associated with operation of the proposed airport has been undertaken.”

Whilst it is understood that details may not be available for the M12 or Northern Road realignment projects and they are subject to a separate approvals process, the report does not provide “a preliminary assessment of the general impact” as it subsequently excludes the potential impacts from these roads.

A statement in the report should be included to acknowledge the limitations of the assessment that only considers existing roads and acknowledges that whilst it does not consider impacts from new motorways or realigned arterial roads, additional impacts as a result of the airport may occur from these roads.

Major

37 | 44



Issue

5.1 /

p32, para 1 and 2

Reference has been made to the NSW Road Noise Policy (RNP) to assess the effect of the proposed airport on road traffic noise in the area. The RNP recommends noise assessment criteria for residential and non-residential land uses affected by traffic generating developments. These criteria are more relevant to the assessment of new road infrastructure works, and they do not assist greatly in determining the impact of road traffic noise increases on existing roads due to the proposed airport and associated development.

In Section 3.4, the RNP document indicates that …. “an increase of up to 2 dB represents a minor impact that is considered barely perceptible to the average person”. It is this statement which is useful in assessing the significance of traffic noise level increases due to the proposed airport development.

The RNP provides specific guidance for land uses affected by additional traffic on existing roads generated by land use developments in Step 4 of Section 3.4.1. The guidance was clarified in the RNP Application Notes (EPA, 2013) as follows:

“The second paragraph in Step 4 should therefore be read to mean: 'After taking Steps 1 to 3, for existing residences and other sensitive land uses affected by additional traffic on existing roads generated by land use developments, any increase in the total traffic noise level as a result of the development should be limited to 2 dB above that of the noise level without the development. This limit applies wherever the noise level without the development is within 2 dB of, or exceeds, the relevant day or night noise assessment criterion.”

The report should be amended to include the appropriate RNP assessment criteria.


5.2 /

p32, para 1

“Road traffic projections for major roads in the vicinity of the airport have been provided by traffic planners for the year 2030 (GHD 2015a (R9)) with and without the airport.”

The suggested approach in Section 2.5.3 of the RNP is to assess a project at the year of opening and a design year, typically ten years after opening. The intention of the design year is provide an indication of road traffic noise impacts in the longer term when the project is established.

The project opening year for the airport is stated to be around 2025 in the EIS.

The road traffic assessment should consider the project’s impacts at the opening year and at a design to assess potential long term impacts, or else provide justification for an alternative approach.

Medium

5.2 /

p32, para 1

Noise levels at typical distances from these roads have been calculated using the CoRTN (R7) procedure which has allowed the increase in road traffic noise due to the proposed airport development to be forecast.

The typical offset distance is not stated. The typical offset distances for each road should be stated


5.2 /

P 33 Table 5-1

“The highest noise level increase expected is less than 2 dB and accordingly, it is concluded that there would not likely be a perceptible noise increase resulting from road traffic as a result of the proposed airport development.”

The traffic volumes used to generate these results are not presented in the report and therefore the results are not able to be verified.

However, for the results presented in the report, this conclusion is considered acceptable.

None For information only




Issue

6 /

P34 Conclusions section

This section may require updating based on the resolution of the previously stated issues.

Update where appropriate based on the outcome of the considerations above


6 /

p35, para 9

“Although heavy and light vehicles would need to access the proposed airport during the construction stage, the resulting increase in traffic noise would not be significant.”

Insufficient evidence presented in the assessment to support this conclusion, as vehicles accessing Elizabeth Drive on surrounding roads were not included in the assessment.

Additional assessment of roads that link to Elizabeth Drive

Medium

6 /

p35, para 10

“During operation of the proposed airport, road traffic noise level increases in the surrounding area are predicted to be insignificant. This is without considering the impact of the newly proposed M12 motorway and any road realignments which would be subject to separate applications and approvals by the relevant authorities.”

This statement acknowledges the limitations of the assessment.

The main body of the EIS does not includes the same statement of limitations.

The limitations of the assessment should be reflected in statements throughout the EIS.

High

6 /

p35, para 10

“During operation of the proposed airport, road traffic noise level increases in the surrounding area are predicted to be insignificant. This is without considering the impact of the newly proposed M12 motorway and any road realignments which would be subject to separate applications and approvals by the relevant authorities.”

Section 5(b) of the EIS Guidelines state:

“The EIS should identify and address cumulative impacts, where potential project impacts are in addition to existing impacts of other activities (including known potential future expansions or developments by the proponent and other proponents in the region and vicinity).”

Impacts of the associated new motorway and road redevelopments/realignments should be considered as part of a cumulative impact assessment in accordance with 5(b) of the EIS Guidelines.

High

Volume 2 – Chapter 9. Approach to impact assessment

39 | 44



Issue

9.3.2, p6, Table 9-2

Table presents EIS Guideline requirements and indicates where in the EIS they are addressed.

Under “Section 5 – Relevant Impacts” it states the following requirements:-

“a detailed assessment of the nature and extent of the likely short-term and long-term relevant impacts (detailing direct and indirect impacts);

a statement whether any relevant impacts are likely to be unknown, unpredictable or irreversible;

analysis of the significance of the relevant impacts; and

any technical data and other information used or needed to make a detailed assessment of the relevant impacts.”

These guidelines have not been followed adequately within Chapter 11.

Update Chapter 11 to include clear statements on whether impacts are short term, long term, direct, indirect, unknown, predictable or irreversible, and the significance of the impacts.


9.3.2, p11, Table 9-2


Under “Section 6 – Avoidance and mitigation measures” it states that the EIS must include an assessment of the expected or predicted effectiveness of mitigation measures.

These guidelines have not been followed clearly within Chapter 11.

Update Chapter 11 to provide a clearer assessment of the expected / predicted effectiveness of mitigation measures.


9.3.2, p11, Table 9-2


Under “Section 7 – Residual impacts and offsets” it states that the EIS must include the reasons why avoidance or mitigation of impacts may not reasonably be achieved, and quantification of the extent and scope of significant residual impacts.


Update Chapter 11 to include clear statements on whether residual impacts are short term, long term, direct, indirect, unknown, predictable or irreversible, and the significance of the residual impacts.

Include the reasons why avoidance or mitigation of impacts may not reasonably be achieved, where necessary.





Issue

9.3.2, p13, Table 9-2


Under “Section 11 – Information sources” it states that, for information given in the EIS, the EIS must state (amongst other points) the source of the information, how recent the information is, and how reliable the information is.


Update Chapter 11 to include this information – specifically regarding the source noise data used as a basis for the engine ground running noise assessment and the aircraft taxiing noise assessment.


Volume 2 – Chapter 11. Noise (ground operations, construction, road and rail)

Summary, p75

“Under worst case meteorological conditions, noise associated with engine run-up has the potential to affect Luddenham, Badgerys Creek, Bringelly and Greendale.”

Appendix E2 states that this noise also has the potential to affect Wallacia. This location has not been brought through from the technical appendix.

Update summary to include Wallacia Noted for

information

Summary, p75

“During operation of the proposed airport, increased noise levels due to airport generated road traffic in the surrounding area are not expected to be significant.”

This statement is misleading as it implies that development of the airport will not result in increases in road traffic noise in the project area. However, a new motorway (M12) is being built to service the airport. Whilst the assessment of the new road would be assessed and approved under a different approvals process, the impact of a new motorway would likely increase noise levels in the surrounding area as a direct result of airport generated traffic.

The summary also does not include the limitations stated in Appendix E2 which acknowledges that the M12 and other road realignments have not been considered in the assessment.

Revision of statements for operational road traffic noise to include limitations and acknowledging that operation of the M12 and realignment of The Northern Road are not included in the impact assessment.

High

11.2.2, p76-77

“A sound power level for each aircraft of 138 dBA has been assumed, being the highest level measured for aircraft taxiing (B777, B747, B737, B717 and A330) […]

[…] the Boeing 747 is the loudest aircraft anticipated to operate at the proposed airport”

It is assumed that the 747 taxi noise has been used for the purposes of the noise modelling exercise.

Clarify that the source noise level for the 747 aircraft has been used as a basis for the taxi noise assessment


11.2.3

P 78, para 1

“The traffic projections were used to calculate noise levels at typical distances from roads near the airport site using the ‘Calculation of road traffic noise’ procedure (CoRTN)”

No predicted traffic noise levels are presented in the EIS or Appendix E2. Noise levels presented are the change in noise level.

Amend statement to reflect that traffic noise levels are not presented in the report, only predicted increase.


41 | 44



Issue

11.3, Figure 11-2, p79

A figure depicting noise sensitive receptors surrounding the airport site

It is difficult to see the location of nearest residential receptors, as their location appears to be indicated by very small points in light grey – whereas the other types of receptor are more clearly marked.

It is also difficult to see this in the inset image displaying Luddenham.

The initial impression that the figure currently gives is that there are little, if any.

Recommend that the figure is updated to show more clearly the location of residential receptors, particularly in Luddenham.

Noted for information.

11.7, p97, Table 11-13

The table details the mitigation/management measures to be put forward.

It is important that these proposals are brought forward and conditioned appropriately.

The use of ground power and pre-conditioned air are not included in the table, nor is any mention of the restriction over APU usage.

Given the anticipated impact of noise from engine ground running, consideration should be given to the inclusion of a condition relating to the installation and use of a ground run-up pen or other such structure to provide effective acoustic screening.

Given that the assessment has been based on no APU usage, a condition should be imposed on APU usage.

Recommend that the mitigation measures be conditioned and adopted.


11 General A number of points/issues from Appendix E2 have been carried through to this document.

Update based on the outcome of the Appendix E2 updates.

High

11 General

Magnitude of significance of ground noise impacts, the extent of their impacts, and whether they are temporary or permanent have not been identified. This is a fundamental flaw in the EIS chapter.

Recommend that a magnitude scale for impact significance is used for pre-mitigation and post mitigation assessments so that it can clearly be seen what the residual noise impact is predicted to be.


Volume 2 Chapter 27. Cumulative impact assessment




Issue

27.3.1

“There is also anticipated to be a general increase in background noise levels associated with the ongoing urbanisation and development of Western Sydney. For example, certain proposed road projects, such as the proposed relocation and upgrade of The Northern Road, would contribute to changed background noise levels in the vicinity of the airport site. An increase in background noise would effectively limit the incremental increase associated with noise generated by the airport operations.”

There are two major road projects being developed due to the airport is being built: the M12 motorway and The Northern Road realignment.

The cumulative assessment does not mention the operation of the M12 motorway and does not indicate the degree of impact from The Northern Road realignment.

The omission of these items is not consistent with Section 5(b) of the EIS Guidelines.

Whilst it is recognised that the mitigation and management of these road projects may not be the responsibility of the proponent, the EIS guidelines require that cumulative impacts from known potential future projects are considered.

Further cumulative assessment should be provided to indicate the potential impact of the operation of the M12 and The Northern Road realignment.

High

Volume 2 Chapter 28. Environmental Management Framework

28.4.2, Table 28-5

The table provides a list of mitigation and management measures applicable to Stage 1 operation

It is important that these proposals are brought forward and conditioned appropriately.

The use of ground power and pre-conditioned air are not included in the table, nor is any mention of the restriction over APU usage.

Given the anticipated impact of noise from engine ground running, consideration should be given to specific item relating to the installation and use of a ground run-up pen or other such structure to provide effective acoustic screening.

Given that the assessment has been based on no APU usage, a specific item should be imposed on APU usage.

Recommend that the mitigation measures be conditioned.


Volume 2 Chapter 29. Conclusion

29.3, p625, Table 29-1

The tables provides a summary of the key environmental impacts

The “Noise – ground operations, construction and road traffic” section of the table does not provide an indication of the magnitude of significance of the noise sources stated, and whether this is with or without mitigation measures in place

Recommend that the magnitude of the noise impacts is included to assist in the decision making process.


Volume 3 Chapter 31. Noise

43 | 44



Issue

31.5.1, p66, para 2

“It is not anticipated that taxiing and engine run-up noise levels would increase, but these types of noise may become more frequent in the 2050 scenario.”

It is assumed that the text refers to the effective source noise associated with a single taxiing movement or engine run-up would not increase, rather than the resultant noise impact associated with the number and intensity of operational noise.

None. For information only. Noted for

information

31.5.2, p67, para 4

“The 2063 aircraft taxiing noise contours reflect the increased number of aircraft movements and would extend further south as a result of the commissioning of the second runway.”

The increased impact is not adequately quantified.

The aircraft noise section has identified the population numbers affected, however this information in absent for ground noise.

There is no indication of the level of exceedance for nearest noise sensitive receptors in order to determine the magnitude of the impact.

Recommend that population number affected by ground noise is included.

Recommend that population number affected is in 5 dB bands in order to understand the magnitude of the potential noise impact.


31.5.2, p67, para 4

“Ground run-up noise would also likely occur more frequently in the long term, although the noise contours are not predicted to change based on the modelling assumptions adopted for this assessment.”

On comparison of the ground run-up noise contours for 2030 and 2063, the shape of the contour changes, therefore the statement is incorrect.

Revise the statement Noted for

information

31.5.2, p68 - 69, Figure

31-38, Figure 31-

39

Figure 31-38 and Figure 31-39 show predicted noise levels for engine ground running and taxiing, respectively.

The figures are incorrectly labelled “maximum noise levels”. They should be labelled “LAeq,15min noise levels”.

Correct the labelling of the figures Noted for

information

31.7, p70-72

These pages contain a summary of the findings from the chapter.

The summary of findings does not make any reference to ground noise.

Include a summary of the ground noise impact assessment


Volume 3 Chapter 40. Conclusion and recommendations

40 The Chapter provides a summary of the key environmental impacts

The summary of findings does not make any reference to ground noise.

Include a summary of the ground noise impact assessment


[email protected]

Appendix CAir quality and greenhouse gas (Katestone Environmental)

Western Sydney Airport: Peer Review of

Air Quality and Greenhouse Gas

Assessment

Prepared for:

WSP | Parsons Brinckerhoff

November 2015

Final

Prepared by:

Katestone Environmental Pty Ltd

ABN 92 097 270 276

Ground Floor, 16 Marie Street | PO Box 2217

Milton, Brisbane, Queensland, 4064, Australia

www.katestone.com.au

[email protected]

Ph +61 7 3369 3699

Fax +61 7 3369 1966

Disclaimer

http://katestone.com.au/disclaimer/

Copyright

This document, electronic files or software are the copyright property of Katestone Environmental Pty. Ltd. and the information contained therein is solely for the use of the authorised recipient and may not be used, copied or reproduced in whole or part for any purpose without the prior written authority of Katestone Environmental Pty. Ltd. Katestone Environmental Pty. Ltd. makes no representation, undertakes no duty and accepts no responsibility to any third party who may use or rely upon this document, electronic files or software or the information contained therein.

Copyright Katestone Environmental Pty. Ltd.

Document Control

Deliverable #: D15019-3

Title: Western Sydney Airport: Peer Review of Air Quality and Greenhouse Gas Assessment

Version: 1.1 (Final)

Client: WSP | Parsons Brinckerhoff

Document reference: D15019-3_Peer_Review_Airquality_v1.1.docx

Prepared by: Michael Burchill, Natalie Shaw, Simon Welchman

Reviewed by: Simon Welchman

Approved by:

Simon Welchman

26/11/2015

http://katestone.com.au/disclaimer/

Katestone Environmental Pty Ltd D15019-3 WSP | Parsons Brinckerhoff – Western Sydney Airport: Peer Review of Air Quality and

Greenhouse Gas Assessment – Final

26 November 2015

Page i

Contents

Executive Summary ............................................................................................................................................... iii 1. Introduction ............................................................................................................................................. 1

1.1 Approach ................................................................................................................................................... 1 1.2 Limitations ................................................................................................................................................... 1 1.3 Components of the EIS Considered in Peer Review ............................................................................ 2

2. EIS Guidelines ........................................................................................................................................... 4

3. Review Findings –Stage 1 Development ............................................................................................ 6 3.1 Local air quality .......................................................................................................................................... 6

3.1.1 Methodology ............................................................................................................................. 6 3.1.2 Key assumptions ........................................................................................................................ 8 3.1.3 Construction .............................................................................................................................. 8 3.1.4 Operations ................................................................................................................................. 8 3.1.5 Fuel dumping ........................................................................................................................... 10 3.1.6 Mitigation and management measures ............................................................................. 10

3.2 Regional air quality.................................................................................................................................. 10 3.3 Greenhouse gas ...................................................................................................................................... 11 3.4 Review of the conclusions of the Western Sydney Airport EIS .......................................................... 11 3.5 Overall comments ................................................................................................................................... 12

4. Review Findings – Longer term development ................................................................................. 13 4.1 Local air quality ........................................................................................................................................ 13

4.1.1 Methodology ........................................................................................................................... 13 4.1.2 Key assumptions ...................................................................................................................... 13 4.1.3 Construction ............................................................................................................................ 13 4.1.4 Operations ............................................................................................................................... 14 4.1.5 Mitigation and management measures ............................................................................. 14

4.2 Regional air quality.................................................................................................................................. 15 4.3 Review of the conclusions of the Western Sydney Airport EIS .......................................................... 15 4.4 Overall comments ................................................................................................................................... 16

5. Qualifications ......................................................................................................................................... 17

Appendix A – Detailed Review ......................................................................................................................... 18

Tables

Table 1 Methodology overview ................................................................................................................................ 6 Table 2 Key personnel and project team .............................................................................................................. 17

Table A1 Review of air quality assessment against Approved Methods............................................................. 19 Table A2 General comments relating to air quality sections of EIS ...................................................................... 29 Table A3 Review of regional air quality assessment against NSW EPA’s tiered assessment approach ......... 32



26 November 2015

Page ii

Glossary

Term Definition

µg/m3 micrograms per cubic metre

Nomenclature

CO carbon monoxide

CO2 carbon dioxide

CO2-e carbon dioxide equivalents

NO nitric oxide

NO2 nitrogen dioxide

NOx oxides of nitrogen

PM10 particulate matter with a diameter less than 10 micrometres

PM2.5 particulate matter with a diameter less than 2.5 micrometres

SO2 sulfur dioxide

TSP total suspended particulates

VOC volatile organic compounds

Abbreviations

AEPR Airport Environment Protection Regulation 1997

AERMOD US EPA approved dispersion model

Air NEPM National Environment Protection (Ambient Air Quality) Measure

Approved Methods Approved Methods for the Modelling and Assessment of Air Pollutants in NSW

DEC Department of Environment and Conservation (NSW)

EDMS Emissions and Dispersion Modelling System

EIS Environmental Impact Statement

EPA Environmental Protection Authority

GHG Greenhouse gases

NPI National Pollutant Inventory database

MACROC Macarthur Regional Organisation of Councils

OEH New South Wales Office of Environment and Heritage

US EPA United States Environmental Protection Agency

WSROC Western Sydney Regional Organisation of Councils



26 November 2015

Page iii

EXECUTIVE SUMMARY

Katestone Environmental Pty Ltd (Katestone) was commissioned by WSP | Parsons Brinckerhoff on behalf of the

Western Sydney Regional Organisation of Councils (WSROC) and Macarthur Regional Organisation of Councils

(MACROC) to complete a peer review of the local and regional air quality studies completed as part of the

Environmental Impact Statement (EIS) for the Western Sydney Airport.

Limitations of peer review

Katestone’s peer review has considered the air quality and greenhouse gas assessments presented in the EIS. A

separate health risk assessment was also conducted and presented in the EIS. Katestone’s peer review has not

considered the separate health risk assessment. The separate health risk assessment has been the subject of a

separate peer review by another party.

To assist with its review, Katestone requested access to all relevant input and output files that were integral to the

air quality assessment studies as this information was not contained in the EIS. The provision of such information

is a routine expectation and is a minimum requirement of the EPA for such studies. For a peer review the data is

integral to demonstrating the integrity of the assessment. However, this information was not made available to

Katestone for its review. Consequently, Katestone has relied only upon the information contained in the relevant

chapters of the EIS to complete its review. Where apparent errors and inconsistencies were found within and

between documents, Katestone has noted these, but in most cases has not been able to discern the full

significance of these on the assessment outcomes.

Overall Comments on air quality study

The air quality study is contained in Volume 2 Chapter 12, Volume 3 Chapter 32 and Volume 4 Appendix F1 of

the Western Sydney Airport EIS. Katestone has noted that these documents contain many typographical errors

and inconsistencies that undermine the credibility of the air quality assessment. These sections require a

thorough technical and editorial review by its authors to address the issues outlined in this review to improve

transparency and credibility of the air quality assessment. To enable confidence in the assessment, all

information and data used in the emission estimation, model inputs and outputs should be made available to any

interested party.

The air quality study did not adequately address the sensitive receptors as it:

Failed to identify all sensitive receptors

Failed to identify a representative subset of sensitive receptors - whilst a small subset of sensitive

receptors was identified, the subset does not appear to be representative of potential air quality impacts

at all existing locations of sensitive receptors

Did not identify future sensitive receptors

Incorrectly classified community receptors separately and as having a lesser importance than

residential receptors. Community receptors included various land-uses such as schools, parks,

childcare facilities, churches and shopping centres.

Stage 1 Development

Local Air Quality

Setting aside the issues identified above, if the assessment results are taken as presented in Tables F1 to F8

and Table G1 to G5 (Volume 4, Appendix F1) of the EIS, they indicate the following:

The maximum 1-hour average concentration of NO2 was predicted to exceed the EPA’s impact



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assessment criterion of 246 µg/m3 at one receptor. Three other receptors have maximum 1-hour

average concentrations of NO2 that are 92% to 98% of the EPA’s impact assessment criterion.

The annual average concentrations of PM2.5 were rounded to one significant figure. A number of

receptors were predicted to have an annual concentration of PM2.5 of 8 µg/m3 – equal to the Air NEPM

Advisory Reporting Standard. These results are potentially indicative of minor exceedances

(<0.4 µg/m³) of the Advisory Reporting Standard.

The 99.9th

percentile 1-hour average concentration of formaldehyde was predicted to exceed the EPA’s

impact assessment criterion at two receptors.


The major contributor to elevated levels of air pollutants is aircraft emissions. However, for receptors

close to existing or new roads, the major contributor is external roadways.

Mitigation measures were recommended. However, the effectiveness of the measures in achieving

compliance was not quantified.

Regional air quality

The methods used to assess the regional air quality are acceptable. The assessment of regional air quality

showed that only marginal increases in ozone concentrations would result from Stage 1 Development.

Greenhouse gases

The methods used to estimate greenhouse gas emissions are acceptable. The estimates of greenhouse gas

emissions are reliable and the contribution of greenhouse gas emissions from the project will be relatively small

with Stage 1 Development emissions approximately 0.11% of Australia’s projected 2030 transport-related GHG

inventory.

Overall comments

The Stage 1 Development assessment was based on the annual throughput of the airport would be 63,302 ATM

in 2030. The stated maximum capacity of the airport following completion of Stage 1 is three times higher at

185,000 ATM in 2050. The local air quality assessment, regional air quality and greenhouse gas assessment all

use this assumption in the generation of the emissions and resultant impacts. Consequently, the assessment has

underestimated the potential impact of the Stage 1 Development by a considerable margin.

Longer Term Development

Local Air Quality

The assessment results are taken as presented in Tables F9 to F11 (Volume 4, Appendix F1) of the EIS, they

indicate the air quality assessment of the Longer Term Development shows:


assessment criterion of 246 µg/m3 at 41 of the 96 receptors.

The maximum 24-hour average PM10 concentrations was predicted to exceed the EPA’s impact

assessment criterion at three receptors.

The maximum 24-hour average concentrations of PM2.5 were predicted to exceed the NEPM Advisory

Reporting Standard at three receptors.

The annual average concentrations of PM2.5 were rounded to one significant figure. The annual average

concentrations of PM2.5 were predicted to exceed the Air NEPM Advisory Reporting Standard at 13

receptors (concentrations are reported as 9 µg/m3

or higher). A number of receptors were predicted to



26 November 2015

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have an annual concentration of PM2.5 of 8 µg/m3 – equal to the Air NEPM Advisory Reporting Standard.

These results are potentially indicative of minor exceedances (<0.4 µg/m³) of the Advisory Reporting

Standard.

Whilst a number of mitigation and management measures were listed within the Western Sydney Airport

EIS, the effectiveness of the measures was not quantified and therefore the air quality assessment

failed to demonstrate that compliance with the relevant air quality criteria could be achieved.


The assessment of regional air quality showed:

The change in daily maximum 1-hour ozone concentration from the addition of the airport was 4.5 ppb

which is significantly above the maximum allowable increment of 1 ppb defined in the NSW EPA’s tiered

approach

The change in daily 4-hour average ozone concentration from the addition of the airport was 3.7 ppb

which is significantly above the maximum allowable increment of 1 ppb defined in the NSW EPA’s tiered

approach.


The impacts had to be assessed in context of the 2030 base case emissions as a base case inventory

has not been projected for 2063

Changes in emissions to other existing sources had not been accounted for

Assumes that the rail network exists

Greenhouse gases

The methods used to estimate greenhouse gas emissions are acceptable.

Overall comments

The Longer Term Development contained in the Western Sydney Airport EIS includes a second runway, which

relies upon the existence of rail services to be feasible. The Western Sydney Airport EIS states “As it is not

possible for the longer term development to achieve the project passenger numbers without the rail network the

traffic scenario that does not include the rail network was disregarded.”

Air quality associated with Stage 1 is critically dependent on the traffic volumes generated by the airport.

Consequently, the impact on air quality due to the Longer Term Development is critically dependent on the

existence of the assumed rail services to the airport. The Western Sydney Airport EIS is not seeking approval for

the rail infrastructure that is necessary for its feasibility and the EIS does not contain a detailed proposal for the

rail infrastructure. As a consequence, the air quality assessment of the Longer Term Development is speculative

at best and does not provide a sufficiently robust basis to support approval of the Longer Term Development at

this stage.



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1. INTRODUCTION

Katestone Environmental Pty Ltd (Katestone) was commissioned by WSP | Parsons Brinckerhoff acting on behalf

of the Western Sydney Regional Organisation of Councils (WSROC) and Macarthur Regional Organisation of

Councils (MACROC) to complete a peer review of the local and regional air quality studies completed as part of

the Environmental Impact Statement (EIS) for the Western Sydney Airport.

1.1 Approach

WSP | Parsons Brinckerhoff requested a peer review that:

Evaluates whether the local and regional air quality studies meet the requirements of the EIS Guidelines

and relevant other guidelines and methodologies.

Evaluates whether the conclusions reached in the studies are valid – i.e. an independent evaluation of

whether the predicted impacts are in accordance with published standards and guidelines, and whether

the conclusions of the assessment are a realistic reflection of the actual impacts.

Evaluates whether the underlying assumptions used to inform the assessment (including any

construction or operational assumptions, and modelling assumptions where appropriate) are plausible.

Review the mitigation and management measures proposed and advises on their adequacy in mitigating

impacts.

Evaluates the level of uncertainty over impacts and the environmental risks that will arise as a result.

Provides a summary of the key impacts and opportunities associated with the project in relation to the

local and regional air quality studies.

WSP | Parsons Brinckerhoff also requested that the following be considered:

...a key part of the peer review role to identify any gaps in information, errors or shortcomings.

The purpose of this review is to present factual unbiased information about the technical rigour of the

studies and both the positive and negative aspects of the proposal. All views expressed within the peer

review should be substantiated with reference to information in the EIS or published elsewhere.

The peer review is intended to assess the merits of the proposal as presented in the EIS – it is not at

this stage intended that the peer review will develop recommendations for alternative designs for the

project.

1.2 Limitations

Katestone’s peer review has considered the air quality and greenhouse gas assessments presented in the EIS. A

separate health risk assessment was also conducted and presented in the EIS. Katestone’s peer review has not

considered the separate health risk assessment. The separate health risk assessment has been the subject of a

separate peer review by another party.

To assist with its review, Katestone requested access to all relevant input and output files that were integral to the

air quality assessment studies as this information was not contained in the EIS. The provision of such information

is a routine expectation, is a minimum requirement of the EPA for such studies and is integral to demonstrating

the integrity of the assessment.



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The EPA’s requirements an air quality assessments are detailed in its Approved Methods for the Modelling and

Assessment of Air Pollutants in New South Wales (DEC, 2005) (Approved Methods). The Approved Methods

specifies the minimum requirements for the information to be contained within impact assessment reports. In

relation to air pollutant emissions, the following is expected to be included in the report:

Detailed calculations of pollutant emission rates for each source

In relation to dispersion modelling, the following is expected to be included in the report:

All input, output and meteorological files used in the dispersion modelling supplied in a Microsoft

Windows-compatible format

However, this information was not made available to Katestone for its review. Consequently, Katestone has relied

only upon the information contained in the relevant chapters of the EIS to complete its review. Where apparent

errors and inconsistencies were found within and between documents, Katestone has noted these, but in most

cases has not been able to discern the full significance of these on the assessment outcomes.

As a minimum, the following information should be provided within the technical air quality reports for review:

Local air quality

o Construction

Assumptions used in the emission estimation such as tonnages of material moved,

equipment numbers and control measures

Spreadsheet of emissions information for input into AERMOD model

AERMOD input files and output files, including post processing information.

o Operation

Assumptions used in the emission estimation such as engine type assumed for

each aircraft, taxiing length

Spreadsheet for emissions information from EDMS

AERMOD input and output files, including post processing information.

1.3 Components of the EIS Considered in Peer Review

This report presents the outcomes of Katestone’s independent peer review of the following components of the

EIS:

Local air quality


Greenhouse gases.

In conducting its peer review of the Western Sydney Airport EIS, Katestone has had specific regard to the

following information and relevant documents:

Western Sydney Airport EIS Volume 2 Chapter 12 Air Quality and Greenhouse Gases

Western Sydney Airport EIS Volume 3 Chapter 32 Air Quality

Western Sydney Airport EIS Volume 4 Appendix C Airport EIS Guidelines

Western Sydney Airport EIS Volume 4 Appendix F1 – Local Air Quality and Greenhouse Gas

Assessment

Western Sydney Airport EIS Volume 4 Appendix F2 – Regional Air Quality



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Approved Methods for the Modelling and Assessment of Air Pollutants in NSW (DEC, 2005) (Approved

Methods).

National Environment Protection (Ambient Air Quality) Measure 1998.



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2. EIS GUIDELINES

The EIS Guidelines that relate to air quality and greenhouse gas emissions are as follows:

“2 DESCRIPTION OF THE ACTION

All construction, operational and (if relevant) decommissioning components of the action

should be described in detail. This should include the precise location (including coordinates) of

all works to be undertaken, structures to be built or elements of the action that may have

impacts on matters of National Environmental Significance. The description of the action must

also include details on how the works are to be undertaken (including stages of development

and their timing) and design parameters for those aspects of the structures or elements of the

action that may have relevant impacts.

5 RELEVENT IMPACTS

…

(g) Impacts to the environment (as defined in section 528) should include but not be limited to

the following:

…

Changes to air quality during construction and operation (associated with both

passenger movements and workers)

Potential fuel dump impacts

…

Quantification and assessment of impacts should:

Be against appropriate background/baseline levels

Be prepared according to best practice guidelines and compared to best practice

standards

Consider seasonal and temporal variations where appropriate (including temporal

changes in the sensitivity of the receptor)

Be supported by maps, graphs and diagrams as appropriate to ensure information is

readily understandable

Guidelines and standards used to quantify baselines and impacts should be explained and

justified.

6 AVOIDANCE AND MITIGATION MEASUES

(a) The EIS must provide information on proposed avoidance and mitigation measures to

manage the relevant impact of the action on a matter protected by a controlling provision

(as listed in the preamble of this document).

...

(c) The EIS must include specific and detailed descriptions of the proposed avoidance and

mitigation measures based on best available practices...”



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The air quality and greenhouse gas assessments appear to satisfy the EIS guidelines because they refer to the

correct legislation and technical guidance. However, it has been very difficult to verify this independently via an

analysis of the EIS due to the many typographical errors and inconsistencies (refer to Section 3, Section 4 and

Appendix A) and because critical information was not made available (Section 1.2).



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3. REVIEW FINDINGS –STAGE 1 DEVELOPMENT

3.1 Local air quality

3.1.1 Methodology

The EIS Guidelines require the assessment of impacts to be prepared according to best practice guidelines and

compared to best practice standards. The key documents that contain best practice assessment guidelines and

standards are:

The Environment Protection Authority’s Approved Methods for the Modelling and Assessment of Air

Pollutants in New South Wales (DEC, 2005) (Approved Methods)

National Environment Protection (Ambient Air Quality) Measure 1998.

The air quality assessment of the Western Sydney Airport is stated to have been conducted in accordance with

the Approved Methods. There is insufficient information contained within the EIS documentation to allow our

review to determine if this is a true statement. As detailed in Section 1.2, critical information was not made

available to Katestone for its review, which makes it very difficult to verify independently whether the assessment

has been conducted in accordance with the Approved Methods.

The table below summarises the elements of the assessment and whether the method used was acceptable.

Sections 3.1.2, 3.1.3 and 3.1.4 elaborate further on these issues. A detailed description of each element is

provided in Appendix A.

Table 1 Methodology overview

Chapter of Approved Methods

Section of Approved Methods

Comments

3. Emissions inventory 3.1 Identify all sources of air pollution and potential emissions

Construction - acceptable.

Operations - acceptable.

3.2 Determine source release parameters

Construction - cannot verify - No details provided.

Operation – cannot verify - some parameters acceptable but not all parameters were provided.

3.3 Estimate emission rates Construction – cannot verify - Insufficient information to fully verify.

Operations – cannot verify - EDMS used, which is acceptable. However, insufficient information to fully verify.

3.6 Presentation of emissions inventory

Construction – cannot verify - errors in presentation of emissions inventory.

Operations – cannot verify - inconsistencies and errors in presentation of emissions inventory.

4. Meteorological data 4.1 Minimum data requirements

Acceptable.

4.2 Siting and operating meteorological monitoring equipment

Acceptable.

4.4 Preparation of Level 2 meteorological data

Acceptable.



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Chapter of Approved Methods


Comments

5. Background air quality, terrain, sensitive receptors and building wake effects

5.1 Background air quality data

Acceptable.

5.2 Terrain and sensitive receptors

Terrain – cannot verify - no information on terrain provided.

Sensitive receptors – not acceptable – all sensitive receptors have not been identified. A small subset of sensitive receptors was included; however, the reason for selecting certain sensitive receptors and not others is unclear. Justification and appropriateness needs to be provided. As a minimum, the subset of sensitive receptors should be representative of potential air quality impacts at all existing and possible future locations of sensitive receptors.

6. Dispersion modelling 6.1 Dispersion models Acceptable. Has used AERMOD.

7. Interpretation of dispersion modelling results

7.1.1 Impact assessment criteria

All acceptable except for NO2. The EIS refers to an NO2 criterion of 320 µg/m³, which is incorrect. The correct criterion for 1-hour average concentrations of NO2 is 246 µg/m³ as specified in the Approved Methods.

7.1.2 Application of impact assessment criteria

Construction – cannot verify odour – insufficient information has been provided to determine whether odour assessment criteria have been applied correctly. Other air pollutants - acceptable.

Operations – cannot verify odour – insufficient information has been provided to determine whether odour assessment criteria have been applied correctly. Incorrect 1-hour average NO2 criterion applied in places. Other air pollutants – acceptable.

Summary of impacts Construction – cannot verify - Inconsistencies with presentation of results and reporting of results.

Operations – cannot verify - Inconsistencies with presentation of results and reporting of results.

8. Modelling pollutant transformations

8.1 NO2 assessment Acceptable.

8.2 Detailed assessment of ozone and NO2

Approach based on tiered assessment approach. Acceptable.

9. Impact assessment report

9.1 - 9.6 Not acceptable – the report includes many typographical errors and inconsistencies. The report requires a thorough editorial and technical review.

Dispersion modelling inputs and outputs were not

supplied.



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3.1.2 Key assumptions

The air quality and greenhouse gas assessment for the Stage 1 Development was based on the key assumption

that Stage 1 Development represented 10 million passengers and 63,302 Aircraft transport movements (ATM) for

2030. The Western Sydney EIS states that the capacity of the single runway is 37 million passengers and

185,000 ATM. Whilst it is stated that the capacity of the Stage 1 Development won’t be reached until 2050, the

ATMs are three times higher than those assessed for the Stage 1 Development. Therefore, the ATM assumption

for Stage 1 is critical to the outcome of the assessments for local air quality, regional air quality and greenhouse

gas.

Other assumptions that will affect the emission rates of air pollutants are: specific aircraft fleet

breakdown as detailed in Appendix C of Volume 4, Appendix F1, engine type and taxiing time. Details

were not provided regarding the engine type(s) and taxiing time assumed in the assessment, therefore,

the appropriateness of the assumptions could not be verified.

3.1.3 Construction

The review of the local air quality assessment for construction found the following:

The emission rates associated with bulk earthworks, concrete batching and asphalt batching appeared

reasonable; however, the emission rates were not able to be verified due to insufficient information

provided in Volume 4 Appendix F1 of the EIS regarding construction activities and mitigation measures

assumed.

The emission rates associated with aviation infrastructure (Table 3-6 (Volume 4, Appendix F1) have

been reported incorrectly as the total PM2.5 emissions associated with aviation infrastructure are higher

than those reported for PM10. PM2.5 is a subset of PM10 and therefore it is not possible for PM2.5

emission rates to be higher than PM10 emission rates. It was not possible to verify whether the correct

emission rates were used in the modelling as the modelling files were not available for review.

The dispersion modelling results (shown in Tables 12-19 to 12-22 (Volume 2, Chapter 12) and Tables 7-

1 to 7-4 and G1 to G4 (Volume 4, Appendix F1)) showed that construction of the aviation infrastructure

will result in higher concentrations of PM10 and PM2.5 than the bulk earthworks. This is inconsistent with

the emissions inventories (shown in Table 3-6 (Volume 4, Appendix F1), that indicates that emissions of

TSP and PM10 for the bulk earthworks are at least twice those for construction of the aviation

infrastructure.

The dust deposition results appear to be very low when compared to PM10 concentrations. The dust

deposition rates appear to be 1000 times lower than what would be expected considering the PM10

concentrations.

Inconsistencies in the air pollutant concentrations at sensitive receptors that are presented in tables

(Table G1 to Table G5 (Volume 4, Appendix F1)) compared with the concentration that may be inferred

by considering the relevant contour plots (Figure G1 to Figure G5 (Volume 4, Appendix F1)).

The odour concentration is described in Table 12-23 (Volume 2 Chapter 12) and Table 7-5 and G5

(Volume 4, Appendix F1) as a 1-hour average concentration. The Approved Methods specifies impact

assessment criteria for odour as “nose-response time” averages not 1-hour averages. Consequently, it

is possible that odour levels have not been correctly assessed and may be much higher than presented.

3.1.4 Operations

The review of the local air quality for operations found:



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The emission rates due to operations were not able to be verified due to insufficient information provided

in Volume 4 Appendix F1 of the EIS regarding assumptions relating to taxiing time, aircraft type and

engines.

The air quality assessment defined three types of receptors: residential receptors, on-site receptors and

community receptors. Community receptors included various land-uses such as schools, parks,

childcare facilities, churches and shopping centres. Whilst the technical air quality report (Volume 4

Appendix F1) presented air pollutant concentrations at each of the three receptor types, the Volume 2

air quality chapter focused on residential receptors and on-site receptors. The delineation between

residential and community receptors is not supported by the Approved Methods, which defines a

sensitive receptor as:

A location where people are likely to work or reside; this may include a dwelling, school,

hospital, office or public recreational area. An air quality impact assessment should also

consider the location of known or likely future sensitive receptors.

Community receptors are therefore sensitive receptors, and as such should be assessed on the same

basis as residential receptors. Therefore the Volume 2 air quality chapters should also present predicted

concentrations at these community receptors. Concentrations at some of these community receptors

were predicted to be higher than concentrations at residential receptors.

The EIS refers variously to two impact assessment criteria for 1-hour concentrations of NO2, namely: the

Airport Environment Protection Regulation 1997 criterion of 320 µg/m3; and the Approved Methods’

impact assessment criterion of 246 µg/m3. Volume 2 Chapter 12 states that where there are multiple

criteria the most stringent criterion has been used. However, it appears that the less stringent criterion of

320 µg/m3 has been used. If the stricter impact assessment criterion were used, there would have been

one exceedance of the impact assessment criterion instead of none.

The odour concentration relating to aircraft exhaust is described in Table 12-35 (Volume 2, Chapter 12)

and Tables 5-13 and F-8 (Volume 4, Appendix F1) as a 1-hour average concentration. The Approved

Methods specifies impact assessment criteria for odour as “nose-response time” averages not 1-hour

averages. Consequently, it is possible that odour levels have not been correctly assessed and may be

much higher than presented.

A number of errors within the report were identified. Examples of errors are provided in Table A1 and

Table A2. A summary of errors are as follows:

o Inconsistencies in emissions inventories presented in Volume 2 Chapter 12 and Volume 4

Appendix F1.

o Inconsistencies in the air pollutant concentrations at sensitive receptors that are presented in

tables compared with the concentration that may be inferred by considering the relevant

contour plots (Volume 4, Appendix F1 (refer to Appendix A of this review report for details)).

o Errors in the total emission rates due to airport and roadways presented in all tables.

o A number of typographical errors in relation to presentation of results where incorrect pollutants

or averaging periods were reported.

o Incorrect units stated for result tables, resulting in concentrations being reported as 1000 times

lower than actual.

o Contour lines on the figures do not cover all identified receptors, indicating that some receptors

may not have been included in the modelling.

Whilst many of these “errors” may be typographical, insufficient information was provided in the reports and,

consequently, Katestone could not conduct cross-checking to determine their importance. For example, the



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dispersion model input files were not available for review and therefore it was not possible to verify the emissions,

modelling or results.

3.1.5 Fuel dumping

The potential impacts due to fuel dumping were not quantified. The EIS stated “fuel dumping is not considered

likely to have a significant immediate or future impact on air quality” due to “the inability of many aircraft to

perform dumps, the rapid vaporistation and wind dispersion of jettisoned fuel, the strict guidelines on fuel

dumping altitudes and locations, and the anticipated reduction in fuel dumping events and volumes in the future.”

3.1.6 Mitigation and management measures

Recommended mitigation and management measures in the Western Sydney EIS included, but were not limited

to:

Construction

o Development and implementation of stakeholder communications plan

o Development and implementation of a dust management plan

o Specific dust management, demolition, earthworks, construction and track out mitigation

measures

Operation

o Development and implementation of an operational air quality and odour management plan as

part of the operational plan for the proposed airport

o Installation of an air quality monitoring station at the airport site to monitor NOx, NO, NO2, CO,

O3, PM10, PM2.5 and VOCs

o Consider best available techniques to reduce emissions of ozone precursors.

Whilst these mitigation and management measures should be part of conditions of approval for the project, the

effectiveness of these measures to mitigate exceedances was not quantified.

3.2 Regional air quality

The regional air quality assessment (Volume 4, Appendix F2) methodology was based on the NSW EPA’s Tiered

Procedure for Estimating Ground-level Ozone Impacts from Stationary Sources (Environ, 2011). The EIS

acknowledges that “Stationary sources are defined as scheduled activities listed in Schedule 1 of the Protection

of the Environment Operations (POEO) Act (1997) (NSW). The most significant sources at the proposed airport

(e.g. aircraft in flight) would not be designated as scheduled activity under the POEO Act and, as such, the tiered

procedure for ozone assessment is only applicable for minor emission sources such as boilers. Notwithstanding,

the tiered procedure provides guidance on how ozone assessment should be conducted in NSW and there are

aspects of the guidance that are relevant and applicable.”

Details of the method for the regional air quality assessment are summarised in Appendix A. Adoption of the

NSW EPA’s tiered assessment approach is appropriate for this project. The regional air quality technical report

(Volume 4, Appendix F2) was well written and edited. It provided all the relevant information regarding how the

regional air quality assessment was undertaken, with the exception of detailing how the airport sources were

parameterised within the model.

The assessment showed:



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The change in daily maximum 1-hour ozone concentration from the addition of the airport was 1.1 ppb,

which is marginally above the maximum allowable increment of 1 ppb defined in the NSW EPA’s tiered

approach

The change in daily 4-hour average ozone concentration from the addition of the airport was 0.9 ppb,

which is below the maximum allowable increment of 1 ppb defined in the NSW EPA’s tiered approach.

Mitigation measures that had a focus on reducing NOx emissions were also recommended for consideration.

Whilst the change in the daily maximum 1-hour ozone concentration was marginally higher that the 1 ppb defined

in the EPA’s tiered approach, the base concentration at the location of the incremental change was

approximately 50 ppb (well below the EPA’s impact assessment criterion of 100 ppb). The maximum 1-hour

concentrations within the region were not predicted to increase as a result of the Stage 1 Development.

3.3 Greenhouse gas

Greenhouse gas emissions were quantified due to construction and operations. The report did not specify the

emission factors that were used to quantify emissions; however, Katestone was able to produce similar emission

estimates using the emission factors in the National Greenhouse and Energy Reporting Determinations with the

exception of emissions associated with waste water treatment. It is possible that assumptions not documented

have been included in the calculations emissions associated with waste water treatment. Overall, waste water

treatment emissions were found to be a relatively small proportion of total greenhouse gas emissions.

Notwithstanding the above, the greenhouse gas assessment appears to have provided reliable estimates of

greenhouse gas emissions from the Stage 1 development, as follows:

Direct (scope 1) and indirect (scope 2) GHG emissions from Stage 1 Development of the airport have

been estimated to comprise 0.13 Mt CO2-e/annum, with the majority of emissions associated with

purchased electricity. The Stage 1 Development Scope 1 and Scope 2 emission estimates represent

approximately 0.11% of Australia’s projected 2030 transport related GHG emission inventory. From this

it can be concluded the GHG emission from the airport will not be material in terms of a national

inventory, however a number of mitigation measures have been suggested.

Measures to reduce or offset direct and indirect GHG emission from airport and aviation activities were listed. It is

recommended that these be included in the conditions of approval.

3.4 Review of the conclusions of the Western Sydney Airport EIS

In relation to air quality and greenhouse gases the Western Sydney Airport EIS concluded:

Air quality – local

o “Predicted dust impacts during construction would be below the air quality assessment criteria

at all sensitive residential receptors. Odour from the asphalt plant is also predicted to be below

the relevant criteria at all sensitive residential receptors

o Operation of the proposed Stage 1 Development would result in an increase in emissions of

NO2, particulate matter (PM10 and PM2.5), CO, SO2 and air toxics. There would also be odour

emissions from exhaust and from the on-site waste water treatment plant.

o There were almost no predicted exceedances of the air quality assessment criteria at any of

the sensitive residential receptors investigated as part of the assessment of the Stage 1

Development. The exception was the maximum (99.9th percentile) 1-hour concentration of

formaldehyde with an exceedance shown at on-site receptor.



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o Predicted off-site odour concentrations were expected to be below odour detection limits for

both aircraft exhaust emissions and odour from the on-site waste water treatment plant.”

Air quality – regional

o “Only marginal ozone impacts would result from the operation of the Stage 1 development.

These emissions would be managed using best available techniques and/or offsets.”

Greenhouse gas

o “It can be concluded that the greenhouse gas emissions from the proposed airport would not

be material in terms of a national inventory.”

3.5 Overall comments

The EIS conclusions presented for the greenhouse gas and regional air quality assessments are acceptable

assuming that the emissions scenario of 63,302 ATM is appropriate.

The air quality study is contained in Volume 2 Chapter 12, Volume 3 Chapter 32 and Volume 4 Appendix F1 of

the Western Sydney Airport EIS. Katestone has noted that these documents contain many typographical errors

and inconsistencies that undermine the credibility of the air quality assessment. These sections require a

thorough technical and editorial review by its authors to address the issues outlined in this review to improve

transparency and credibility of the air quality assessment. To enable confidence in the assessment, all

information and data used in the emission estimation, model inputs and outputs should be made available to any

interested party. Based on these issues and those identified in Section 3.1 it is not possible to verify the

conclusions of the EIS in relation to local air quality.

Setting aside the issues identified above, if the assessment results are taken as presented in Tables F1 to F8

and Table G1 to G5 (Volume 4, Appendix F1), they indicate the:

Maximum 1-hour average concentration of NO2 is predicted to exceed the EPA’s impact assessment

criterion of 246 µg/m3 criterion at one sensitive receptor (Table F1, Volume 4 Appendix F1, Appendix F)

Three other sensitive receptors have maximum 1-hour average concentrations of NO2 that are predicted

to be 92% to 98% of the EPA’s impact assessment criterion.

The annual average concentrations of PM2.5 were rounded to one significant figure. A number of

receptors were predicted to have an annual concentration of PM2.5 of 8 µg/m3 – equal to the Air NEPM

Advisory Reporting Standard. These results are potentially indicative of minor exceedances (<0.4 µg/m³)

of the Advisory Reporting Standard.

The 99.9th

percentile 1-hour average concentration of formaldehyde was predicted to exceed the EPA’s

impact assessment criterion at two receptors.


The major contributor to elevated levels of air pollutants is aircraft emissions. However, for receptors

close to existing or new roads, the major contributor is external roadways.

Mitigation measures were recommended. However, the effectiveness of the measures in achieving

compliance was not quantified.

With regards to the key assumption of the Stage 1 Development assessment, if the ATMs for Stage 1

Development are higher than 63,302 ATM there is a high probability that the assessment will result in

additional exceedances of the EPA’s impact assessment criterion for NO2.



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4. REVIEW FINDINGS – LONGER TERM DEVELOPMENT

4.1 Local air quality

4.1.1 Methodology

The methodology used for the Longer Term Development was the same as used for the Stage 1 assessment. It

is relatively unusual for an air quality assessment to project potential impacts almost 50 years into the future. The

assessment of major road projects is an area where similar projections are attempted, albeit over shorter time

horizons of 20 or 30 years. In such instances, future projections are normally conducted by quantifying the

change induced by the project over time and assuming the status quo or a reasonable foreseeable change for

other key features. For example, it might be assumed that background air quality and impact assessment criteria

would remain unchanged but that improvements in motor vehicle emissions would occur. There is no strict

framework or guideline for assessing future impacts decades into the future.

The Longer Term Development has adopted an equivalent assessment framework to the Stage 1 assessment.

No attempt has been made to project key variables except the increase in flights.

The comments presented in Section 3.1.1 regarding methodology are also relevant to peer review of the Longer

Term Development.

4.1.2 Key assumptions

The air quality and greenhouse gas assessment for the Longer Term Development was based on the following

key assumptions:

Longer Term Development is based on 82 million passengers and 365,000 ATM

There is no improvement in aircraft emissions

A specific aircraft fleet breakdown as detailed in Appendix C of Volume 4, Appendix F1

The air quality assessment criteria is unchanged

Background air quality is unchanged from that derived from recent measurements; hence, there would

be no change in the sources of air pollutants in the broader region nor their spatial distribution

Projected increases in flights at the airport and traffic volumes on external major roads associated with

the airport contribute to increased emissions

No account was taken of the locations of possible future sensitive receptors

A rail network that is yet to be planned or approved would be implemented to transport a significant

proportion of airport passengers.

4.1.3 Construction

Construction emissions were not quantified for the Longer Term Development. The EIS stated that the activities

will need to be well managed to satisfy airport safety requirements; however, the EIS did not demonstrate that

impacts would be below the relevant air quality criteria.



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4.1.4 Operations

The review of the local air quality for Longer Term Development operations found:

The emission rates due to operations were not able to be verified due to insufficient information provided

in Volume 4 Appendix F1 of the EIS regarding assumptions relating to taxiing time and aircraft type and

engines.

As with the Stage 1 Development, the air quality assessment defined three types of receptors:

residential receptors, on-site receptors and community receptors. Community receptors included various

land-uses such as schools, parks, childcare facilities, churches and shopping centres. Whilst the

technical air quality report (Volume 4 Appendix F1) presented air pollutant concentrations at each of the

three receptor types, the Volume 3 air quality chapter focused on residential receptors and on-site

receptors. The delineation between residential and community receptors is not supported by the

Approved Methods, as detailed above. Community receptors are also sensitive receptors under the

Approved Methods and, as such, should be assessed on the same basis as residential receptors.

Therefore the 3 air quality chapters should also present predicted concentrations at these community

receptors. Concentrations at some of these community receptors were predicted to be higher than

concentrations at residential receptors.

The air pollutant levels predicted for the Longer Term Development are fundamentally reliant upon the

development of a rail network to transport airport passengers to and from the airport. The rail network is

not yet at the planning stage and there is no guarantee that the rail network will go ahead and, as a

consequence, there is no guarantee that the predicted levels of air pollutants that are associated with

traffic will be achieved in practice..

A number of errors within the report were identified. Examples of errors are provided in Table A1 and

Table A2. A summary of errors are as follows:

o Inconsistencies in emissions inventories presented in Volume 3 Chapter 32 and Volume 4

Appendix F1. Inconsistencies in concentrations presented in tables compared with figures for

various receptors.

o Errors in the total emissions due to airport and roadways presented in all tables.

o Contour lines on the figures illustrating predicted concentrations did not cover all receptors

assessed, indicating that all receptors may not have been modelled.

Whilst many of these “errors” may be typographical, insufficient information was provided in the reports and,

consequently, Katestone could not conduct cross-checking to determine their importance. For example, the

dispersion model input files were not available for review and therefore it was not possible to verify the emissions,

modelling or results.

4.1.5 Mitigation and management measures

A number of mitigation and management measures that could be considered in the future as the number of

passengers using the airport increases were listed within the Western Sydney Airport EIS based on a literature

review of emission mitigation measures adopted at various international airports. It was also acknowledged that

some of the measures listed were up to the individual airline and out of control of the airport operator.

Notwithstanding the list of mitigation and management measures, the effectiveness of the measures was not

quantified and therefore the air quality assessment failed to demonstrate that compliance with the relevant air

quality criteria could be achieved.



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4.2 Regional air quality

The regional air quality assessment for the Longer Term Development used the same methodology as for the

Stage 1 Development.

The assessment showed:

The change in daily maximum 1-hour ozone concentration from the addition of the airport was 4.5 ppb,

which is significantly above the maximum allowable increment of 1 ppb defined in the EPA’s Tiered

approach

The change in daily 4-hour average ozone concentration from the addition of the airport was 3.7 ppb,

which is significantly above the maximum allowable increment of 1 ppb defined in the EPA’s Tiered

approach.

Mitigation measures that had a focus on reducing NOx emissions were recommended for consideration.


The potential impacts had to be assessed in context of the 2030 base case emissions as a base case

inventory has not been projected for 2063

Changes in emissions to other existing sources had not been accounted for

Assumes that the rail network exists.

4.3 Review of the conclusions of the Western Sydney Airport EIS

In relation to air quality, the Western Sydney Airport EIS concluded:

Air quality – local

o The results indicate that exceedances of the 1-hour average NO2 criterion of 246 µg/m3 maybe

experienced at 11 residential receptors. These exceedances are predicted to occur for

between one and four hours per year.

o Under conservative assumptions there may be exceedances of the 1-hour AEPR objective of

320 µg/m3 at up to seven residential receptors. These exceedances are predicted to occur for

between one and two hours per year.

o Predicted (cumulative) PM10 concentrations are anticipated to be above the NSW EPA impact

assessment criterion of 50 µg/m3

on occasion at one on-site receptor.

o Predicted (cumulative) PM2.5 concentrations are anticipated to be above NEPM advisory

reporting goals at a number of receptors.

Air quality – regional

o The change in daily maximum 1-hour ozone concentration from the addition of the airport was

4.5 ppb which is significantly above the maximum allowable increment of 1 ppb defined in the

NSW EPA’s tiered approach

o The change in daily 4-hour average ozone concentration from the addition of the airport was

3.7 ppb which is significantly above the maximum allowable increment of 1 ppb defined in the

NSW EPA’s tiered approach.



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4.4 Overall comments

If the assessment results are taken as presented in Tables F9 to F11 (Volume 4, Appendix F1), the air quality

assessment of the Longer Term Development shows:


assessment criterion of 246 µg/m3 at 41 of the 96 receptors (Table F9, Volume 4 Appendix F1,

Appendix F)

The maximum 24-hour average PM10 concentration was predicted to exceed the EPA’s impact

assessment criterion at three receptors.

The maximum 24-hour average concentrations of PM2.5 were predicted to exceed the NEPM Advisory

Reporting Standard at three receptors (Table F11, Volume 4 Appendix F1, Appendix F).

The annual average concentrations of PM2.5 were rounded to one significant figure. The annual average

concentrations of PM2.5 are exceeded at 13 receptors (concentrations are reported as 9 µg/m3

or

higher). A number of receptors were predicted to have an annual concentration of PM2.5 of 8 µg/m3 –

equal to the Air NEPM Advisory Reporting Standard. These results are potentially indicative of minor

exceedances (<0.4 µg/m³) of the Advisory Reporting Standard.

The Longer Term Development adopted the same air quality assessment framework as the Stage 1

Development. In particular, the assessment considered the existing air quality assessment criteria, background

air quality derived from recent measurements and with no account taken of possible changes in the sources of air

pollutants nor their spatial distribution over time. The assessment of the Longer Term Development indicates that

concentrations will exceed the current air quality assessment criteria at existing sensitive receptors.

The most important issue with regards to the Longer Term Development is the assumption regarding the

development of a new rail network. The Western Sydney Airport EIS states “As it is not possible for the longer

term development to achieve the project passenger numbers without the rail network the traffic scenario that

does not include the rail network was disregarded.”

Air quality associated with Stage 1 is critically dependent on the traffic volumes generated by the airport.

Consequently, the impact on air quality due to the Longer Term Development is critically dependent on the

existence of the assumed rail services to the airport. The Western Sydney Airport EIS is not seeking approval for

the rail infrastructure that is necessary for its feasibility and the EIS does not contain a detailed proposal for the

rail infrastructure. As a consequence, the air quality assessment of the Longer Term Development is speculative

at best and does not provide a sufficiently robust basis to support approval of the Longer Term Development at

this stage.



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5. QUALIFICATIONS

This review has been undertaken by Simon Welchman, Natalie Shaw and Michael Burchill.

Simon is a Director at Katestone has a background of proven success over 20 years working as an

environmental engineer in the private sector and for the environmental regulator. His expertise includes: air

quality impact assessment of major industrial, infrastructure and mining projects; licensing, approvals and

regulations; peer review and advice on air quality planning matters; odour impact assessment; greenhouse and

air pollution control and management. Simon also provides expert witness services for matters relating to air

quality and odour assessment in the Planning and Environment Court in Queensland and the Land and

Environment Court in New South Wales. Most recently Katestone completed the air quality and greenhouse gas

impact assessment for the Sunshine Coast Airport Expansion Project, for which Simon was the project director.

A summary of qualifications and role of each team member in project is provided in Table 2.

Table 2 Key personnel and project team

Name Qualifications Role on Project Skills

Simon Welchman

Director

BEng (Environmental)

(Hons)

20+ years experience

Project Director

Project direction and management

Expert advice on emissions regulation

Emissions benchmarking and assessment of best available control technologies

Air quality impact assessment studies of major industrial and infrastructure projects

Developing government policy for air quality and odour impact assessment

Developing environmental regulation

Air pollution emissions monitoring and ambient air quality monitoring

Natalie Shaw

Principal Air Quality Consultant

BAppSc (Chemistry),

MAppSc

15 years experience

Project Team

Project management

Air quality modelling including TAPM, CALMET, CALPUFF, Ausplume, ISC3, CAL3QHCR, AERMOD

Photochemical modelling using TAPM-CTM

Air quality impact assessments for major industrial and infrastructure projects

Air pollution emission estimation

Assessment of site meteorology for industries including site specific meteorological data for inclusion in dispersion modelling

Air pollution emissions monitoring and ambient air quality monitoring

Dr Michael Burchill

Air Quality Consultant

BAppSc (Physics)(Hons),

PhD

4 years experience

Project Team

Air quality modelling including TAPM, CALMET, CALPUFF, Ausplume, CAL3QHCR, AERMOD

Air quality impact assessments for major industrial and infrastructure projects

Air pollution emission estimation

Assessment of site meteorology for industries including site specific meteorological data for inclusion in dispersion modelling



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APPENDIX A – DETAILED REVIEW

Katestone Environmental Pty Ltd D15019-3 WSP | Parsons Brinckerhoff – Western Sydney Airport: Peer Review of Air Quality and Greenhouse Gas Assessment – Final

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Table A1 Review of air quality assessment against Approved Methods

Approved Methods Section of EIS Addressed

Comment Chapter of Approved Methods


3. Emissions inventory

3.1 Identify all sources of air pollution and potential emissions

Volume 2, Chapter 12

- Section 12.3.2

Volume 4, Appendix F1

- Section 3.6

Construction - acceptable

Construction impacts were quantified for Stage 1 Development. Construction impacts were not quantified for the Longer Term Development.

The following sources were included:

o Bulk earthworks including dozers, scrapers, loading and unloading material, hauling on paved and unpaved roads, wind erosion and grading

o Aviation infrastructure including working crew, asphalt plant and concrete batching plant

Potential emissions identified as TSP, PM10, PM2.5 and odour


- Section 12.6.1


- Section 3.1.2.3

- Appendix C

Operation – Stage 1 Development - acceptable


o Aircraft main engines, including approach mode, taxi/idle, take-off and climb-out mode

o Auxiliary power units (APUs)

o Ground support equipment (GSE) including but not limited to aircraft push back, mobile generators, tractors, powered passenger stairs, tractors, catering trucks, etc

o Parking facilities

o Stationary sources including boilers, engine tests, fuel tanks, generators, paints and solvents

o Training fires

o Terminal traffic

o Road traffic

o Waste water treatment plant

Potential emissions identified as NOx, SO2, CO, VOCs, lead, PM10, PM2.5 and odour


- Section 3.1.2.3

- Appendix C

Operation – Longer Term Development - acceptable


o Aircraft main engines, including approach mode, taxi/idle, take-off and climb-out mode

o Auxiliary power units (APUs)

o Ground support equipment (GSE) including but not limited to aircraft push back, mobile


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generators, tractors, powered passenger stairs, tractors, catering trucks, etc

o Parking facilities

o Stationary sources including boilers, engine tests, fuel tanks, generators

o Training fires

o Terminal traffic

o Road traffic

Potential emissions identified as NOx, SO2, CO, VOCs, lead, PM10, PM2.5 and odour

3.2 Determine source release parameters

Not provided. Construction – cannot verify

No detail was provided in the report

Modelling files were not available for review


- Appendix C

Operation – Stage 1 Development – cannot fully verify – some parameters acceptable but not all parameters provided

Source characteristics were provided for parking facilities, boilers, generators, fuel tanks, surface coating/painting and training fires

There was no information on source release parameters for the aircraft main engines, auxiliary power units, terminal traffic or road traffic in the report

Emission concentrations limits for the boilers and generators were not specified.

Modelling files were not available for review

Not provided. Operation – Longer Term Development – cannot verify

No specific information was provided for the Longer Term Development scenario

3.3 Estimate emission rates


- Section 3.6

Construction – cannot fully verify due to insufficient information

Emission factors were stated to be based on local and US EPA factors which is acceptable, if the correct factors are used. However the specific references were not provided.

Emissions were estimated for construction in relation to the Stage 1 Development only.

There was no information on construction information used to calculate emission rates. For example quantity of material moved, stockpile areas, number of trucks etc

There was no information on control measures incorporated in the emission rate calculation.

The correct pollutants were included in the assessment (TSP, PM10, PM2.5 and odour)


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- Appendix C

Operation – Stage 1 Development – cannot fully verify due to insufficient information

Emissions were estimated using the Emissions and Dispersion modelling system (EDMS (v5.1.4)) for the airport related activities. EDMS is appropriate for this use.

Emissions were based on 10 million passengers and 63,302 aircraft movements

The correct pollutants were assessed (NOx, CO, PM10, PM2.5, SO2, VOCs and odour)

Lead was deemed to not require assessment due to only 5% of planes having a pistol engine. However, it is recommended that the emission rates of lead be quantified and compared to the emissions for other pollutants.

There were a number of assumptions made regarding:

o Taxiing (a 50 / 50 split was assumed in each direction) The report states “It is acknowledged that in reality the runway combinations are a function of the prevailing weather conditions” and therefore operations may occur in a single combination for an extended period of time. Averaging operations may underestimate impacts under these circumstances, in particular for the shorter term averaging periods.

o Duration of taxiing was estimated; however, assumption was not specified

o Engine type; however, assumption was not specified

There was no detail provided as to the sensitivity to emissions based on the above assumptions


- Appendix C

Operation – Longer Term Development – cannot fully verify due to insufficient information

Emissions were estimated using the Emissions and Dispersion modelling system (EDMS) for the airport related activities. EDMS is appropriate for this use.

Emissions were based on 82 million passengers and 369,952 aircraft movements

NOx, CO, PM10, PM2.5, SO2 and, VOCs were correctly included in the assessment, as above lead should also have been considered.

.

There were a number of assumptions made regarding:

o Taxiing (a 50 / 50 split was assumed in each direction) The report states “It is acknowledged that in reality the runway combinations are a function of the prevailing weather conditions” and therefore operations may occur in a single combination for an extended period of time. Averaging operations may underestimate impacts under these circumstances, in particular for the shorter term averaging periods.

o Duration of taxiing was estimated; however, assumption was not specified

o Engine type; however, assumption was not specified


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There was no detail provided as to the sensitivity to emissions based on the above assumptions

3.6 Presentation of emissions inventory


- Section 3.6.2

- Section 3.6.3

- Section 3.6.4

Construction – cannot fully verify – errors in presentation of emissions inventory

Emission inventories for TSP, PM10 and PM2.5 have been presented for:

o Bulk earthworks (Table 3-6)

o Aviation infrastructure works (Table 3-6)

o Concrete batching plant (Table 3-7)

o Asphalt batching plant (Table 3-8)

As there was insufficient information provided in the Volume 4, Appendix F1 the emissions were for bulk earthworks, aviation infrastructure works, concrete batching and asphalt batching were not able to be reproduced. Notwithstanding this:

o The emission inventory for bulk earthworks appears reasonable

o The emissions inventory for concrete batching plant appears reasonable

o The emissions inventory for asphalt batching plant appears reasonable

o As presented in Volume 4, Appendix F1, the emissions due to the construction of aviation infrastructure does not appear to be correct as the total emissions of PM2.5 are higher than that for PM10. As PM2.5 is a subset of PM10 this is not correct. As the emissions spreadsheets and model inputs were not available for review it was not possible to determine whether this was a typographical error or an error in the assessment.


- Section 12.6.1


- Section 5.1.1

Operation – Stage 1 Development – cannot verify – inconsistencies and errors in presentation of inventory

Emissions inventories for NOx, CO, PM10, PM2.5, SO2 and VOCs are presented in both Volume 2, Chapter 12 and Volume 4, Appendix F1

The emission inventory (Table 12-24 in Volume 2 Chapter 12 and Table 5-1 in Volume 4 Appendix F1) appears to include typographical errors.

o The total including external roadways is different in the two tables; however, the tables are supposed to represent the same emissions

o Emissions from stationary sources should consist of the individual emissions from boilers, engine tests, fuel tanks, generators and paint solvents. However, in providing the total emissions from the airport, these stationary sources have been double counted in both tables. The percentage contribution of all of the individual sources is therefore also incorrect.

o The total (tonnes per year) for the airport is incorrect for all pollutants in both tables

Figures 12-6 and 12-7 (Volume 2 Chapter 12) and Figures 5-1 and Figure 5-2 (Volume 4 Appendix


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F1) which reflect the emissions and percentages presented in the emission inventories are incorrect and should be updated.

The inventory (Table 5-1 Volume 4, Appendix F1) has a PM2.5/PM10 ratio of 0.43 for external roads. From the NSW Greater Metropolitan Region Inventory the PM2.5/PM10 ratio was 0.74.

As there was insufficient information provided in the Volume 4, Appendix F1 the emissions for Stage 1 Development were unable to be reproduced exactly. Whilst some pollutants for some sources were able to be replicated this could not be done for all pollutants and all sources.


- Section 32.4.1


- Section 5.1.2

Operation – Longer Term Development – cannot verify – inconsistencies and errors in presentation of emissions inventory

Emissions inventories for NOx, CO, PM10, PM2.5, SO2 and VOCs are presented in Table 32-1 in Volume 3 Chapter 32 and Table 5-3 in Volume 4 Appendix F)

These tables appear to include typographical errors.

o Emissions from stationary sources should consist of the individual emissions from boilers, engine tests, fuel tanks, generators and paint solvents. However, in providing the total emissions from the airport, these stationary sources have been double counted in both tables. The percentage contribution of all of the individual sources is therefore also incorrect.

o The total (tonnes per year) for the airport is incorrect for all pollutants in both tables

Figures 32-1 and 32-2 (Volume 3 Chapter 32) and Figures 5-4 and Figure 5-5 (Volume 4 Appendix F1) which reflect the emissions and percentages presented in the emission inventories do not match the data in the tables

As there was insufficient information provided in the Volume 4, Appendix F1 the emissions for Longer Term Development were unable to be reproduced exactly. Whilst some pollutants for some sources were able to be replicated this could not be done for all pollutants and all sources.

4. Meteorological data

4.1 Minimum data requirements


- Section 4.1

Acceptable

Data from Bureau of Meteorology (BoM) Badgerys Creek site and Camden Airport site was used.

At least one year of data – this has been addressed adequately

At least 90% complete – this has been addressed adequately

Correlated against a longer-duration site-representative meteorological database of at least five years – this has been addressed adequately

4.2 Siting and Volume 4, Appendix F1 Acceptable


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operating meteorological monitoring equipment

- Section 4.1

It is stated in Section 4.1 that the Badgerys Creek site is compliant with the Australian Standards AS 2923-1987 Guide for Measurement of Horizontal Wind for Air Quality Applications.

4.4 Preparation of Level 2 meteorological data


- Appendix D Section D.1 .2

Acceptable

A meteorological file suitable for use in the dispersion model AERMOD was generated using USEPA approved meteorological pre-processor AIRMET to process the Badgerys Creek and Camden Airport data into suitable format for AERMOD.

5. Background air quality, terrain, sensitive receptors and

building wake effects

5.1 Background air quality data


- Section 4.2

Acceptable

Ambient monitoring data from the NSW Office of Environment (OEH) sites at Bringelly, Liverpool and Richmond has been used in the assessment. Data was used from the year 2014 to coincide with the meteorological year used in the assessments. It is noted that based on the ambient monitoring summary pollutant concentrations in particular NO2, appear to be lower than other years. No commentary was provided for the decrease in NO2 concentrations. This should be provided to provide some comfort that selection of another year would not result in exceedances for the 1-hour NO2 concentrations.

Specific requirements of the Approved Methods are:

o Obtain ambient monitoring data that includes at least one year of continuous measurements and is contemporaneous with the meteorological data used in the dispersion modelling – this has been adequately addressed.

o At each receptor, add each individual dispersion model prediction to the corresponding measured background concentration (e.g. add the first hourly average dispersion model prediction to the first hourly average background concentration) to obtain hourly predictions of total impact - this has been adequately addressed.

o At each receptor, determine the 100th percentile total impact for the relevant averaging - this has been adequately addressed.

5.2 Terrain and sensitive receptors


- Appendix E

Terrain – cannot verify - no information on terrain provided.

Sensitive receptors – not acceptable – all sensitive receptors have not been identified. A small subset of sensitive receptors was included; however, the reason for selecting certain sensitive receptors and not others is unclear. Justification and appropriateness needs to be provided. As a minimum, the subset of sensitive receptors should be representative of potential air quality impacts at all existing and possible future locations of sensitive receptors.

5.3 Building wakes Building wakes have been stated to be included in the modelling. However, as no modelling files


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were available for review these could not be verified.

6. Dispersion modelling

6.1 Dispersion models

Volume 2 Chapter 12

-Section 12.3

Volume 4 Appendix F1

- Appendix D

The US EPA approved dispersion model AERMOD was used. Whilst the model is not specified within the Approved Methods, it is been accepted for use in Australia.

7. Interpretation of dispersion modelling results

7.1.1 Impact assessment criteria

Volume 2 Chapter 12


- Section 2.2

- Section 2.3

The following impact assessment criteria were used:

o Approved Methods

o Airports (Environment Protection) Regulations 1997

o National Environment Protection (Air Toxics) Measure

It is relevant to note that, in places, the EIS refers to an NO2 criterion of 320 µg/m³, which is incorrect. The correct criterion for 1-hour average concentrations of NO2 is 246 µg/m³ as specified in the Approved Methods.

7.1.2 Application of impact assessment criteria

Volume 2 Chapter 12

- Section 12.5

-Section 12.6

Volume 3 Chapter 32

- Section 32.4.2


- Section 5

- Section 7

- Appendix F

- Appendix G

Construction – cannot verify for odour – insufficient information has been provided to determine whether odour assessment criteria have been applied correctly. Other air pollutants - acceptable.

Operations – cannot verify for odour – insufficient information has been provided to determine whether odour assessment criteria have been applied correctly. Incorrect 1-hour average NO2 criterion applied in places. Other air pollutants – acceptable.

Summary of impacts See below See results for Construction, Stage 1 Development and Longer Term Development below.

Construction results Volume 2 Chapter 12

- Section 12. 5


- Section 7

For bulk earthworks (as reported in EIS)

o Maximum 24-hour and annual concentrations of PM10 and PM2.5 are well below the relevant air quality criteria

o Annual dust deposition rates are well below the criterion

For aviation infrastructure (as reported in EIS)


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- Appendix G o Maximum 24-hour and annual concentrations of PM10 and PM2.5 are well below the relevant air quality criteria

o Annual dust deposition rates are well below the criterion

The results indicate that construction of the aviation infrastructure is likely to result in higher concentrations of particulate than the bulk earthworks associated with construction. This does not agree with the emissions inventory presented for both which indicates that emissions of TSP and PM10 for the bulk earthworks are at least twice those for aviation infrastructure.

The dust deposition results appear to be very low when compared to PM10 concentrations. The dust deposition rates appear to be 1000 times lower than what would be expected.

For asphalt batching plant (as reported in the EIS)

o The odour concentration is below relevant odour criterion.

The odour concentration is presented as 99th

1-hour concentration. The Approved Methods specifies impact assessment criteria for odour as “nose-response time” averages not 1-hour averages.

Both the concrete batching plant and asphalt plant emit dust. It is not clear whether the emissions of dust from these facilities are included in the bulk earthworks or aviation infrastructure results.

Stage 1 Development

Volume 2 Chapter 12

- Section 12. 6


- Section 5

- Appendix F

For the Stage 1 development (as reported in the EIS) local air quality is as follows:

o Maximum 1-hour and annual average concentrations of NO2 are below the air quality assessment criteria at all residential receptors, with maximum 1-hour NO2 predicted to be 60% and 70% of the AEPR criterion of 320 µg/m

3. (The EIS did not compare against the EPA

criterion of 246 µg/m3.)

o Maximum 24-hour average and annual average concentrations of PM10 and PM2.5 are below the assessment criteria at all residential receptors

o Maximum 10-minute, 1-hour, 24-hour and annual average concentrations of SO2 are well below the assessment criteria at all residential receptors

o Concentrations of air toxics at residential receptors are well below the air quality assessment criteria for the 99.9

th percentile

o The 99.9th

percentile 1-hour average concentration of formaldehyde is predicted to exceed the on-site receptor R24.

o The predicted 99th percentile odour concentration for aircraft exhaust is well below the criterion

at all residential receptors.

o The predicted 99th percentile odour concentration for waste water treatment is well below the

criterion at all residential receptors.

The summary of local air quality in Volume 2 Chapter 12 focused on the residential receptors.


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However, there are 75 community receptors identified in Volume 4 Appendix F1. Taking into consideration these receptors and the most stringent air quality criteria, the review found the following:

o Maximum 1-hour average concentration of NO2 is above the EPA criterion of 246 µg/m3 at one

receptor (Table F1, Volume 4 Appendix F1, Appendix F)

o Three other receptors have maximum 1-hour average concentrations of NO2 that are 92% to 98% of the EPA criterion.

o The annual average concentrations of PM2.5 were rounded to one significant figure. A number of receptors were predicted to have an annual concentration of PM2.5 of 8 µg/m

3 – equal to the

Air NEPM Advisory Reporting Standard. These results are potentially indicative of minor exceedances (<0.4 µg/m³) of the Advisory Reporting Standard.

o The 99.9th

percentile 1-hour average concentration of formaldehyde is predicted to exceed at two receptors

o The predicted concentrations of all other air pollutants were below their respective assessment criteria.


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Longer Term Development

Volume 3 Chapter 32

- Section 32.4


- Section 5

- Appendix F

For the Longer term development (as reported in the EIS)

o Annual average concentrations of NO2 are below the air quality assessment criteria at all residential receptors

o Maximum 1-hour concentrations of NO2 are predicted to exceed the AEPR criterion of 320 µg/m

3 at seven of the 20 receptors. (The EIS did not compare against the EPA criterion of

246 µg/m3.)

o Annual average concentrations of PM10 are below the assessment criteria at all residential receptors

o Maximum 24-hour average concentrations of PM10 are below the criterion at all receptors with the exception of R24 (on-site receptor)

o Maximum 24-hour and annual average concentrations of PM2.5 will be above the relevant criteria for a number of receptors (one receptor for 24-hour average and four receptors for annual average).

The summary of local air quality in Volume 3 Chapter 32 focused on the residential receptors. However, there are over 100 community receptors identified in Volume 4 Appendix F1. Taking into consideration these receptors and the most stringent air quality criteria, the review found the following:

o Maximum 1-hour average concentration of NO2 is above the EPA criterion of 246 µg/m3 at 41

of the 96 receptors (Table F9, Volume 4 Appendix F1, Appendix F)

o The NO2 criterion contour has not been added to Figure F55. This should be added to demonstrate the extent of the exceedance.

o The maximum 24-hour average PM10 concentrations exceed the criterion at three receptors.

o The PM10 criterion contour has not been added to Figure F61. This should be added to demonstrate the extent of the exceedance.

o The maximum 24-hour average concentrations of PM2.5 are exceeded at 3 receptors (Table F11, Volume 4 Appendix F1, Appendix F).

o The annual average concentrations of PM2.5 were rounded to one significant figure. The annual average concentrations of PM2.5 are exceeded at 13 receptors (concentrations are reported as 9 µg/m

3 or higher). A number of receptors were predicted to have an annual

concentration of PM2.5 of 8 µg/m3 – equal to the Air NEPM Advisory Reporting Standard.

These results are potentially indicative of minor exceedances (<0.4 µg/m³) of the Advisory Reporting Standard. (Table F11, Volume 4 Appendix F1, Appendix F).


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8. Modelling pollutant transformations

8.1 NO2 assessment Volume 4 Appendix F1 Acceptable.

8.2 Detailed assessment of ozone and NO2

Volume 4 Appendix F2 Approach based on tiered assessment approach. Acceptable.

9. Impact Assessment Report

9.1 – 9.6 Volume 4 Appendix F1 Not acceptable - the report includes many typographical errors and inconsistencies. The report requires a thorough editorial and technical review.

Dispersion modelling inputs and outputs were not supplied.

Table A2 General comments relating to air quality sections of EIS

Section of EIS Comment

Volume 2 Chapter 12

Table 12-29 – Incorrect units presented for CO concentrations. Concentrations should read “mg/m3” not

“µg/m3”

Table 12-34 – Incorrect pollutant names in header row of table. The columns should read Benzene, Toluene, Xylene not Toluene, Xylene and Formaldehyde


- Section 3.1.2.3

- Appendix F1 Section C.4

- Appendix F1 Section C.5

It is not clear what emission factors were used to determine emissions for parking facilities and road traffic

o Section 3.1.2.3 states that “…roadways and parking emissions have been based on the Australian traffic emissions data developed by PIARC”.

o Appendix F Section C.4 states “Emissions from a given car park were calculated in EDMS for vehicles moving and idling”

o Appendix F Section C.5 states “emissions from road traffic were calculated using the emission factors developed by the EPA for the latest emissions inventory for the Greater Metropolitan Region (GMR).”


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- Section 5.2

Table 5-7 – Incorrect units presented for CO concentrations. Concentrations should read “mg/m3” not

“µg/m3”

Table 5-10 – Table heading indicates the 99th

percentile 1-hour average concentrations are presented. Should read 99.9

th percentile.

Table 5-12 – Incorrect pollutant names in header row of table. The columns should read Benzene, Toluene, Xylene not Toluene, Xylene and Formaldehyde

Table 5-13 – Averaging period for odour is stated as 1-hour 99.9th

. This should be 1-s nose-response-time average. Not clear whether typographical error or incorrect averaging period for concentrations.


- Section F1 Stage 1 Development

Table F1 – Predicted NO2 concentrations due to the airport in isolation are higher than predicted NO2 concentrations due to cumulative assessment. Affected receptors are R59, R99, R124, R126, R127 and R138

Table F1 and Figure F1 – Inconsistencies between reported 1-hour concentration in the Table F1 and Figure F1. Examples are provided below.

Receptor Cumulative 1-hour NO2 (µg/m

3)

Table F1 Figure F1

R104 305 100

R118 241 Between 100 and 120

Figures F2 – F6, F8 – F12, F14 – F60, F62 – F66 and F68 have contours that do not cover the entire domain. This has resulted in lines disappearing. For some receptors it is difficult to compare concentrations presented in the Figures with the corresponding concentrations presented in the Tables. There are also inconsistencies between the concentrations in the tables and figures.

Table F4 and Figure 14 – Inconsistencies in predicted 1-hour CO concentration at R24 due to airport in isolation

Table F5-b and Figure F26 - Inconsistencies in predicted 1-hour SO2 concentrations at some receptors due to cumulative impact. Examples are provided below.

Receptor Cumulative 1-hour SO2 (µg/m

3)

Table F5-b Figure F26

R4 50 80


26 November 2015

Page 31


R6 115 Between 60 and 80

R17 122 Between 60 and 80

R117 141 Between 100 and 120

Table F7-a – Incorrect pollutant names and NEPM-AAQ Investigation level in header row of table.

Table F7b – Incorrect NEPM-AAQ Investigation level in header row of table.


- Appendix F

Table F9 – incorrect averaging period in table header. Should read “1-hour” not "24-hour”

Figure F56 and Table F9 – Inconsistencies in 1-hour NO2 concentrations in the table and figure

Figure F56 – Contour line displaying criterion is not presented on figure. This should be included as it would indicate areas where exceedance of the criterion is predicted for NO2.

Figure F57 and Table F10 – Inconsistencies in 24-hour PM10 concentrations in the table and figure

Figure F61 - Contour line displaying criterion is not presented on figure. This should be included as it would indicate areas where exceedance of the criterion is predicted for PM10.


- Section G.1.2

Table G2 – Typographical error regarding table description. Should read “Predicted cumulative results during bulk earth works” not “Predicted cumulative results during site preparation works”

Table G3 – Typographical error regarding averaging period in header row of table. Sixth column across should read “Annual” not “24-hour hour” for the pollutant PM2.5.

Table G4 – Typographical error regarding averaging period in header row of table. Sixth column across should read “Annual” not “24-hour” for the pollutant PM2.5.

Table G5 and Figure G17 - Inconsistencies in odour concentrations in the table and figure. Examples are provided below.

Receptor 99

th percentile Odour (ou)

Table G5 Figure G17

R14 1.7 Between 0.02 and 0.04

R17 0.4 Between 0.02 and 0.04

R18 0.5 0.04


26 November 2015

Page 32


Table G5 – Averaging period referred to as “1-hour”. The odour criterion is a "nose-response” average. It is not clear whether the 1-hour concentrations have been converted to a “nose-response” average using the peak to mean ratios in the Approved Methods.

Table A3 Review of regional air quality assessment against NSW EPA’s tiered assessment approach

Documentation required for NSW EPA’s Tiered Ozone

Assessments

Comment

Photochemical model used Comprehensive Air Quality Model with extensions (CAMx) used. This is acceptable

Chemical mechanism used CB05. This is acceptable.

Source of input data Emissions Acceptable

Scenarios – 2008/2009 base case, 2030 future base case, 2030 Airport case, 2063, Airport case

Base emissions used 2030 projected inventory for Greater Metropolitan Region (with the exception of biogenics

Biogenics derived using Model of Emissions of Gases and Aerosols from Nature (MEGAN)

Airport emissions for 2030

Road emissions due to airport only (excluded existing as incorporated in base emissions)

Meteorology Acceptable

TAPM derived meteorology using OEH and BoM data for data assimilation.

TAPM configuration in accordance with recommendations in TAPM manual. Justification provided for deviation in nesting of grids ratio


26 November 2015

Page 33


Assessments

Comment

Used November 2008 to February 2009

Source of input data Boundary conditions

Acceptable

Obtained using global model MOZART

Modelling periods Acceptable

November 2008 to February 2009 for model validation

12 case days for impact assessment

Procedures for evaluating base case model performance Acceptable

Sources of ambient data Acceptable

OEH data

Statistical evaluation methods Acceptable

Graphical evaluation methods Acceptable

Characteristics of new source Location Not provided

Stack parameters

Emissions rates Acceptable

VOC speciation Acceptable

Procedures for selecting days to evaluate ozone impacts Acceptable


26 November 2015

Page 34


Assessments

Comment

Ozone increases from new source

emission on evaluation days

Results for 1-hour and 4-hour ozone

Acceptable

Maximum ozone increases

Acceptable

Base case ozone at location of maximum increase

Not provided in tables; however, can see in figures provided.

Significance assessment of new source ozone increases against 1-hour and 4-hour average incremental ozone criterion

Acceptable.

As the project is in a nonattainment area assessed against maximum increment of 1ppb

Ozone impact (increase plus background) due to new source emissions on evaluation day

Acceptable

Significance assessment of new source ozone impact against 1-hour and 4-hour average Air NEPM ozone standards

Acceptable

Appendix DTraffic and Transport (ARUP)

WSROC and MACROC Councils

Western Sydney Airport EIS Peer Review

Peer Review: Traffic and Transport sections within the Western Sydney Airport EIS

Final | 20 November 2015

This report takes into account the particular

instructions and requirements of our client.

It is not intended for and should not be relied

upon by any third party and no responsibility

is undertaken to any third party.

Job number 24624100

Arup

Arup Pty Ltd ABN 18 000 966 165

Arup

Level 10 201 Kent Street

PO Box 76 Millers Point

Sydney 2000

Australia

www.arup.com

| Final | 20 November 2015 | Arup

J:\246000\246241-00 WSA EIS PEER\WORK\INTERNAL\PEER REVIEW REPORTING\FINAL DRAFT TO PB\PEER REVIEW WSA EIS_FINAL.DOCX

Document Verification

Job title Western Sydney Airport EIS Peer Review Job number

24624100

Document title Peer Review: Traffic and Transport sections within

the Western Sydney Airport EIS

File reference

Document ref

Revision Date Filename Peer Review WSA EIS.docx

Draft 1 29 Oct

2015

Description First draft

Prepared by Checked by Approved by

Name Sam Gray Peter Dunn Andrew Hulse

Signature

Draft 2 11 Nov

2015

Filename Peer Review WSA EIS.docx Description Final



Signature

Final 20 Nov

2015

Filename Peer Review WSA EIS.docx Description



Signature

Filename

Description


Name

Signature

Issue Document Verification with Document

WSROC and MACROC Councils Western Sydney Airport EIS Peer Review Peer Review: Traffic and Transport sections within the Western Sydney Airport

EIS



Contents

Page

1 Executive Summary 1

2 Peer Review Methodology 4

2.1 Approach 4

2.2 Limitations 4

2.3 Draft EIS Sections Reviewed 5

3 Detailed Findings: Construction & Stage 1 6

3.1 Compliance of the report with the (EPBC Act) EIS Guidelines 6

3.2 Commentary on validity of assumptions 10

3.3 Discussion whether the conclusions reached in the studies are valid 16

3.4 Review of proposed mitigation and management measures 17

3.5 The level of uncertainty over impacts and the environmental risks 18

4 Detailed Findings: Long Term development 19

4.1 Approach of Airport long term development assessment 19

4.2 Potential ‘gaps’ of long term development assessment relative to a conventional EIS assessment 19

4.3 Key risks and implications as a result of the gaps 21

4.4 Effectiveness of the assessment in setting a framework for further assessment. 21

5 Summary of key impacts and opportunities 23

5.1 Construction 23

5.2 Stage 1 23

5.3 Long term Airport development 24

6 Peer Reviewers Qualifications 25


EIS



Page 1

1 Executive Summary

Background and Scope

Arup has been commission by WSP | Parsons Brinckerhoff on behalf of the

Western Sydney Regional Organisation of Councils (WSROC) and Macarthur

Regional Organisation of Councils (MACROC) to provide Peer Review Services

of the traffic and transport sections of the draft environmental impact statement

(EIS) for Western Sydney Airport.

The purpose this review was to inform these member authorities regarding the

technical adequacy and completeness of this traffic and transport impact

assessment. As such this peer review purpose is to present factual, unbiased

information about the technical rigour of the study (both the positive and negative

aspects contained within). All views expressed within the peer review will be

substantiated with reference to information in the draft EIS or published

elsewhere.

The peer review has been intended to assess the merits of the proposal as

presented in the draft EIS – it has not been intended that the peer review will

develop recommendations for alternative designs for the project.

The results of the peer review will be provided to the member authorities of

WSROC and MACROC to assist them in making their submissions to the draft

EIS.

In relation to Arup’s comments regarding any short comings of this assessment, it

should be noted that Arup has not been privy to any specific requirements above

and beyond those described in the Guidelines for the Content of a Draft

Environmental Impact Assessment Statement, Western Sydney Airport,

Environment Protection and Biodiversity Conservation Act, 1999.

It is understood traffic and transport is likely one of the key environmental issues

associated with the Airport. Arup has provided independent traffic and transport

reviews relating to the adequacy of the documentation provided in and the

appropriateness of the mitigation measures proposed in:

“WSA EIS 19 volume 2 chapter 15”


“WSA EIS GHD volume 4 appendix j surface transport and access”

Stage 1 Airport

Issues identified in terms of predicted traffic impacts as a result of the Stage 1

airport include:

Limitation of the strategic traffic model’s (STM3) ability to capture traffic

impacts at a detailed level

Detailed intersection traffic modelling not undertaken


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Page 2

Intersection operations and performance not assessed

Future land take impacts as a result of intersection operations

Freight traffic generation and associated impacts (outside of specific air

cargo) not assessed

Traffic generation and associated impacts caused by the zoned lands

within the Airport precinct not assessed

Impact to public transportation operations (bus network) not assessed

The above issues and limitations are considered significant. Further information

would need to be provided to enable Arup to reach a firm opinion as to whether

the conclusions reached in the study are valid. Until these comments are

addressed or further information supplied, Arup is unable to comment on the

validity of the traffic impact conclusions reached in this draft EIS.

Long Term Airport Development

The predicted traffic impacts of the long term development of the Western Sydney

Airport largely followed the Stage 1 assessment. A number of the issues identified

for Stage 1 are also apparent in the longer term development including:

Limitation of the strategic traffic model’s (STM3) ability to capture traffic

impacts at a detailed level

Detailed intersection traffic modelling not undertaken

Intersection operations and performance not assessed

Future land take impacts as a result of intersection operations

Freight traffic generation and associated impacts (outside of specific air

cargo) not assessed

Traffic generation and associated impacts caused by the zoned lands

within the Airport precinct not assessed

Impact to public transportation operations (bus network) not assessed

Additionally, a number of issues identified in the longer term development (above

and beyond Stage 1) include:

The local road network adjacent to the Airport reaches capacity by 2063.

No road planning mitigation measures were provided

Airport Access Drive (from M12) reaches capacity by 2050, 13 years

before long term development year of 2063. Capacity is predicted to be

reached for approximately 15 hours a day.

Insufficient information was provided to determine how air passenger

demands would access and egress the Airport beyond 2050 (when the

Airport Access Road reaches capacity)


EIS



Page 3

No assessment was included to understand what impact the air passenger

demands using the SWRLe would have on the wider Sydney Rail

Network.

Prior to the long term development of the airport being constructed, a major

development plan (managed in accordance with the Commonwealth Airports Act

1996) will be required with final approval provided by the Minister of

Infrastructure and Regional Development.

As such, Arup believes the above issues and limitations should be viewed in

conjunction with this context

Key Impacts and Opportunities

The traffic impacts caused by Stage 1 of the Airport is predicted to be relatively

low. With consideration to the methodology used, the draft EIS states the future

road network is able to accommodate the predicted Airport traffic demand.

Nonetheless, it was difficult for Arup to confirm the validity of these impacts with

confidence. Arup has identified further information that could be provided to

quantify the potential impacts, including:

Freight traffic generation within the Airport precinct (outside of air cargo)

Private vehicle traffic generation from land uses within the Airport precinct

(outside of air passengers)

Vehicle travel time comparison (as predicted by strategic modelling)

Intersection performance (as predicted by intersection modelling)

Intersection layout requirements (as predicted by intersection modelling)

The following describes the predicted traffic impacts caused by the long term

development of the Airport as described in the draft EIS:

The traffic impacts caused by the Airport is predicted to be significant. The

Airport Access Drive from the M12 is predicted to fail in 2050. This is

approximately 13 years before the ultimate long term airport development

year (2063).

The traffic impacts also effect the wider road network with significant

congestion predicted on key road links in 2063. The assessment acknowledges

this is a result of significant background growth in conjunction with unknown

road infrastructure commitments past 2041.

The Airport also impacts wider transport modes. The assessment suggests

additional rail link capacity (above and beyond the SWRLe) would be

required to accommodate both the Airport trips and background growth trips

by 2063.

With consideration to the above potential impacts, it is recommended that detailed

transport network planning including road and rail network planning be

undertaken.


EIS



Page 4

2 Peer Review Methodology

2.1 Approach

Arup reviewed the traffic and transport assessment of the draft EIS of the

proposed Western Sydney Airport with respect to its technical adequacy and

completeness. The review considered relevant guidelines, requirements and

legislation.

Specifically, Arup undertook the following tasks:

Consider whether the traffic and transport study meet the requirements of the

EPBC EIS Guidelines and relevant other guidelines and methodologies.

Reviewed the validity of the draft EIS conclusions – i.e. an independent

evaluation of whether the predicted impacts are in accordance with published

standards and guidelines, and whether the conclusions of the assessment are

likely to be a realistic reflection of the actual impacts.

Evaluated the appropriateness of the underlying assumptions used to inform

the assessment (including any construction or operational assumptions and

modelling assumptions) are plausible.

Reviewed the mitigation and management measures proposed and advised on

their adequacy in mitigating impacts.

Assessed the level of uncertainty over impacts and the environmental risks

identified in the draft EIS.

Reviewed the transport modelling and analysis presented in the report of the

construction scenario and the Stage 1 and long term development scenarios for

the Airport and assessed each models fitness to draw conclusions of the

Airports impacts

Provided a summary of the key impacts and opportunities associated with the

projects traffic and transport impact assessment based on the information

provided.

2.2 Limitations

The following details the limitations within Arup’s peer review assessment:

The peer reviews was based on the draft EIS reports provided, with no

fieldwork undertaken or any direct communication with the specialists

preparing the report, or regulators.

No detailed model auditing was undertaken, Arup only provided comment on

the modelling methodology and results presented in the draft EIS

documentation

Arup did not undertake any additional modelling or analysis to assess the

adequacy of the modelling results provided


EIS



Page 5

2.3 Draft EIS Sections Reviewed

Arup reviewed the following specific sections of the Environmental Impact

Statement (EIS) for the proposed Western Sydney Airport, including:



“WSA EIS GHD volume 4 appendix j surface transport and access”


EIS



Page 6

3 Detailed Findings: Construction & Stage 1

The following details Arup’s peer review of the construction and operational

traffic impacts caused by Stage 1 of the proposed Western Sydney Airport.

3.1 Compliance of the report with the (EPBC Act)

EIS Guidelines

The following describes Arup’s consideration of the key Traffic and Transport

sections of the Western Sydney Airport draft EIS compared to the requirements

set out in the EPBC Guidelines.

a. The EPBC guidelines, Section 5 Relevant Impacts suggests that the EIS should

assess changes in traffic movements during construction and operation

(associated with both passenger movements and workers) where this

assessment should be prepared according to best practice guidelines and

compared to best practice standards.

The Sydney Strategic Travel Model (STM3) model has been used to forecast and

assess the changes in traffic movements as a result of construction and operational

traffic generated by the Airport. STM3 is the accepted travel demand forecasting

tool for Greater Sydney Metropolitan Area (GMA) that is operated and

maintained by the Bureau of Transport Statistics within Transport for New South

Wales. STM’s features include:

Examining the effects of significant land use changes and significant transport

initiatives which may include packages of road, rail and travel demand

management measures

Travel demand forecasts for the Greater Sydney Metropolitan Area by travel

zone by mode choice and distribution.

Private vehicle assignment on the strategic road network based on link based

delay functions

Transport mode choice and distribution for trips to/from the Airport. It

therefore has additional rigour when conducting its vehicle assignment.

When calibrated and validated, the STM3 is best suited to forecasting changes

in demand or growth rather than absolute forecasts on a corridor.

With consideration of the above, the STM3 is likely to be a well suited model that

is able to capture the effects of the Airport at a strategic level.

However, Arup also appreciates the strategic nature of the STM3 and the

limitations inherent within the model, namely:

The STM3 is a large area travel demand model that includes complex

functions and interactions that approximate travel behavioural characteristics

based on relatively large input dataset. The model therefore approximates

travel patterns experienced in the real world.


EIS



Page 7

The STM3 contains road link geometry that is relatively simplified, using only

link lengths and number of lanes as inputs. For example, turning bays at

intersections are not specifically modelled.

The STM3 models vehicle operations on the road links in a relatively

simplified manner. Predicted traffic delays and congestion follow only basic

‘volume to speed’ relationships.

Vehicle operations at intersections are not specifically modelled. For example,

traffic delays and congestion caused by inefficient intersection geometry

and/or inefficient signal phasing is not captured.

Furthermore, as disclosed in the draft EIS assessment, there is a risk that the

STM3 is not effectively calibrated and validated for the purposes of this draft EIS.

The assessment states “STM3 models were provided by Transport for NSW for

this task. The models are currently in development by Transport for NSW.

However, due to the time constraints for the Western Sydney Airport EIS, GHD

has used the latest available versions as the basis for the analysis in this study.

GHD has not reviewed or corroborated the models provided beyond consistency

checks of outputs” (WSA EIS GHD volume 4 appendix j surface transport and

access). This is a limitation of the draft EIS methodology and is considered a risk.

With consideration to both the STM’s features and limitations listed above, Arup

further acknowledges the industry standards that suggest strategic models like the

STM3 be only applied for strategic purposes. It is generally accepted that strategic

models can form strong baselines for transport impact assessments, but are not

considered the best tool for detailed assessments. (BTS Technical Documentation,

February 2011)

The BTS describes that “For specific projects, the STM outputs should be used as

a starting point to produce estimates of overall demand in response to alternative

land use and/or transport supply scenarios. However, the STM, due to its

limitations as a strategic modelling tool, may need to be supplemented with more

detailed analyses for project evaluation purposes” (BTS InfoSheet, December

2013)

Hence the STM analysis undertaken for the draft EIS would have captured the

effects of changing traffic movements as a result of the Airport at a strategic

rather than detailed level. STM, as a strategic travel demand model, does not

include representation of intersections and would not provide confidence in traffic

forecasts at a corridor level. This is why a model hierarchy exists in Sydney with

STM providing strategic travel forecasts, and more detailed traffic and public

transport patronage assessments being undertaken in the Roads and Maritime’s

traffic model and the BTS’s PTPM model respectively. Furthermore, various

project specific models can be developed on a project by project basis for detailed

traffic analysis.

b. Section 5 of the EPBC guidelines , Section 5 Relevant Impacts suggests that

the EIS should assess changes in traffic movements during construction and

operation (associated with both passenger movements and workers) where

this assessment should be prepared according to best practice guidelines and



EIS



Page 8

The draft EIS did not include intersection modelling to assess the Airports

potential traffic impacts. This is a key limitation of the assessments methodology

and is considered a significant risk.

Traffic intersection modelling could supplement the broad strategic baseline set

by strategic traffic models, and further capture impacts on road networks at a

detailed level. For example, unlike strategic traffic models, intersection traffic

models can capture the relationship between intersection capacity and intersection

lane geometry. Namely, they can be used to assess if additional land take would

be required to widen intersections to allow for acceptable traffic operations.

Hence, unlike strategic models, they can be used to capture the direct effects of

traffic impacts on land acquisition. In relation to adhering to the EPBC

requirements for ‘best practice’, Arup acknowledges the use of both strategic

traffic modelling and intersection traffic modelling in other EIS submissions. The

following large scale infrastructure projects in Sydney used detailed intersection

traffic modelling coupled with strategic traffic modelling to capture future traffic

impacts:

Sydney Metro Northwest (North West Rail Link): Intersection modelling of

construction and operational impacts

WestConnex Stage 1a: Intersection modelling of construction and operational

impacts

WestConnex Stage 1b: Intersection modelling of construction and operational

impacts

NorthConnex (M1-M2 Link): Intersection modelling of construction and

operational impacts

c. The EPBC guidelines, Section 5 Relevant Impacts suggests that the EIS should


(associated with both passenger movements and workers) where the

assessments should be supported by maps, graphs and diagrams as

appropriate to ensure information is readily understandable, and where this

assessment should be prepared according to best practice guidelines and


The following tables and diagrams are contained within the assessment (but not

limited to):

Mid-block Volume/Capacity Diagrams (existing)

Mid-block Level of Service Diagrams (existing)

Mid-block Level of Service Tables (existing)

Mid-block Volume/Capacity Diagrams (future)

Mid-block Level of Service Diagrams (future)

Mid-block Level of Service Tables (future)

Mid-block Volume Difference Diagrams (future)


EIS



Page 9

When considering Level of Service, Arup acknowledges that the worst Level of

Sevice reported is F and also acknowledges that comparative distinctions can be

made when Level of Service changes within the A to F spectrum. For example,

‘as a result of the future traffic generated by the shopping centre, the existing

road deteriorates in performance from Level of Service C to E’.

However, when roads links already operate at Level of Service F the addition of

traffic and associated impacts can be hidden within Level of Service results. For

example Level of Service F to F. For this reason, a table of midblock volume to

capacity values should be provided to gauge and quantify any potential traffic

impacts caused above and beyond Level of Service F.

The draft EIS provided mid-block volume to capacity diagrams, but did not

provide tables with explicit volume to capacity values. When comparing to other

large scale infrastructure EIS assessment, Arup notes the provision of these values

is generally accepted as industry best practice.

Vehicle travel time comparisons were not provided in this draft EIS assessment.

These are important metrics that identify future congestion levels and accessibility

to the airport. This is a limitation of the assessments methodology and is

considered a risk. Arup notes that strategic modelled travel time comparison

metrics were used in the WestConnex, NorthConnex and NWRL EIS assessments.

The STM3 could be used to predict vehicle travel times along road links ‘with’

and ‘without the Airport’ to further quantify the traffic impacts.

d. The EPBC guidelines, Section 3 Feasible Alternatives suggests the EIS should

consider feasible alternatives, provide comparative analysis and commentary

of the alternative, and also make clear which alternative is preferred.

Importantly, one such alternative could be the ‘do nothing’ alternative (i.e do not

build the Airport). Arup acknowledges that the traffic and transport sections of

this assessment did provide analysis and commentary pertaining to the ‘do

nothing’ alternative. Through the use of the STM3 strategic model, this

assessment provided commentary on performance of the road network ‘with

Airport’ and ‘without Airport (do nothing).

However, Arup also understands that the potential use of Wilton or the RAAF

Base Richmond were also considered alternatives. The Traffic and Transport

sections of this draft EIS did not provide analysis and commentary pertaining to

either of these alternatives.

e. The EPBC guidelines, Section 5 Relevant Impacts suggests the EIS should

identify and address the cumulative impacts of the project in addition to

existing impacts of other activities. Critically, the impacts should include

future developments from other proponents in the region or vicinity.

This assessment provided analysis and commentary pertaining to the existing

impacts of other activities (including future developments) in the region or

vicinity. As described, these future regional impacts will arise from key land use

developments from the South West Growth Centre (SWGC), the Broader Western

Sydney Employment Area (BWSEA) and the Greater Macarthur Land Release

Area. The STM3 strategic model captured the combined effects of traffic


EIS



Page 10

generation from the proposed Airport land uses and also traffic generation of these

future land uses in the in the region. Hence, through the use of the STM3, this

assessment made commentary on the cumulative impacts of the Airport land uses

above and beyond future non-airport land uses.

However, no commentary pertaining to future land use assumptions were

provided. This assessment makes the following comment in relation to the traffic

impacts of the Airport in 2031 “the substantial package of road improvements

proposed as part of the WSIP, in addition to those identified in the BWSEA and

SWGC, would have sufficient capacity to cater for the expected airport passenger

and employee traffic demand in 2031”. As land use is one of the key underlying

drivers of traffic generation, the explicit future land uses in the region should be

provided. This would hence cater for improved comparisons between future land

use traffic generation and future roadway capacity. To support this claim Section

5 of the EPBC guidelines suggests that the EIS should assess changes in traffic

movements during construction and operation (associated with both passenger

movements and workers) where standards and guidelines used to quantify

baselines and impacts should be explained or justified. Arup believes the

disclosure of the explicit land use assumptions of future land uses in the area is

justified by the EPBC Act.

f. The EPBC guidelines, Section 5 Relevant Impacts suggests that the EIS should


(associated with both passenger movements and workers) where this

assessment should be against appropriate background/baseline levels.

As described in point (e) above, the draft EIS has captured effects of traffic

generation from the future non-airport related land uses in the in the region and

has therefore established and ‘appropriate background/baseline level’.

Nonetheless, this should be viewed in conjunction with lack of information

provided on the specifics of these land use assumptions.

3.2 Commentary on validity of assumptions

The following describes Arup’s consideration on the validity of the assumptions

used in the Traffic and Transport sections of the Western Sydney Airport draft

EIS.

3.2.1 Traffic Generation Assumptions

a. Non Direct Airport Related Traffic – As described in the methodology section

of the Traffic and Transport assessment, trips originating in and destined for

the Airport site were defined as

Construction traffic

Air passenger arrival and departing vehicle traffic

Airport related employee traffic (only those who work directly for the Airport)

Freight traffic (only those vehicles required to service the predicted tonnage of

air cargo)


EIS



Page 11

From above, the traffic impact assessment of Stage 1 only considered traffic

generation from these ‘direct airport-related trips’. Any traffic generation caused

by other land uses (either by staff, businesses or general public) within the Airport

site has not been presented in the draft EIS. As in, the assessment has not

considered the impacts from non-directly related airport traffic, but traffic that

would otherwise not be in existence without the Airport being constructed.

As described in section 2.3 of Draft Airport Plan – Western Sydney Airport

(October 2015), 229 hectares and 167 hectares would be zoned for ‘Terminal and

Support Services’ and ‘Business Development’ respectively.

Section 2.4.2.2 states that ‘Terminal and Support Services’ would include

“Developments to facilitate the provision of goods and services necessary to meet

the quality and standards that international, domestic and regional travellers

have come to reasonably expect” including, but not limited to the following uses:

Business premises

Markets

Kiosks

Freight handling and transport facility

Hotel or motel accommodation

Office premises

Section 2.4.2.5 states that ‘Business Development’ would “enable a mix of

business, retail and industrial uses in locations that are close to and that support

the functioning of the Airport” including, but not limited to the following uses:

Business premises

Retail premises

Recreational facility

Hotel or motel accommodation

Freight handling and transport facility

Warehouse and distribution centres

Light Industry

Office premises

The scale and function of the above land use developments could generate a

significant cumulative amount of traffic. This draft EIS did not make any

assumptions to account for this potential traffic and associated potential impacts.

Adjustments to the land use assumptions that inform STM and the use of traffic

generation first principles or empirical benchmarking data (of other airports)

could have been used to capture and assess this potential traffic impact.

b. Flight Related Traffic – Commentary on the validity of the assumptions used

in the draft EIS are found in Section 2.2.2 Aviation Demand and Activity of


EIS



Page 12

the Arup document entitled “Western Sydney Airport EIS Peer Review -

Aviation Planning and dated 6 November 2015”:

With respect to passenger transfer reductions and in relation to traffic generation,

it is noted the draft EIS did not account for the potential transfer of air passengers

between flights. Namely, no assumptions were made pertaining to whether any

passengers may arrive by one flight, transfer, and then depart on a subsequent

flight. A behaviour sequence like this would result in the passenger not impacting

on the landside road network.

This passenger transfer information would likely be available for other airports of

similar size and type to the proposed Airport. Hence, Arup believes a

benchmarking exercise could be undertaken that would result in an informed

assumption of ‘transfer of air passengers’. Arup understands that without such an

assumption, all arriving airside passengers convert into landside trips. This

represents a worst case scenario, but also an unlikely scenario.

c. Airport Related Staff Traffic – Arup acknowledges the level of detail and

rigour used to predict the quantity and mode share of trips created by Airport

staff. Considering that the Airport is in early stages of planning, Arup believes

the assumptions used in these predictions are fit for purpose for the draft EIS

assessment.

However, Arup does not agree with the validity of the assumption that states “For

each shift, 50 percent of employees have been assumed to arrive in the hour

before their shifts starts…” Arup believes it is unlikely that many staff members

(if any) would arrive more than a full hour prior to their shift start. Nonetheless,

Arup does not believe this assumption would significantly affect the outcomes of

this assessment.

d. Air Freight Cargo Traffic – For commentary on the validity of the

assumptions used to predict peak hour air freight cargo for the Airport are

found in Section 2.2.2 Aviation Demand and Activity of the Arup document

entitled “Western Sydney Airport EIS Peer Review - Aviation Planning and

dated 6 November 2015”.

Regarding the predicted vehicle trips generated by the air freight cargo only, Arup

notes a discrepancy between the freight trips tabulated in Table 6-10 and the

freight trips described in section 7.4 of WSA EIS GHD volume 4 appendix j

surface transport and access. Table 6-10 indicates a total of 9 and 13 freight trips

to/from the Airport in the 2 hours AM and PM peaks respectively. While section

7.4 describes a total of 3,966 freight trips to the Airport in the 2 hour AM peak

and a total of 1,905 freight trips from the Airport in the 2 hour PM peak. It is

unknown where this discrepancy has come from. It should be noted the 3,966 and

1,905 trip volumes seem to relate to the total traffic trips to/from the Airport

shown in Table 6-10.

e. Public Transport Trip Generation –

Air Passenger Public Transportation Use


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As described in Table 6-3 of ‘WSA EIS GHD volume 4 appendix j surface

transport and access’, public transportation use (for air passenger trips)

originating in and destined for the Airport in 2031 were assumed as:

5% Shuttle

5-10% Bus

0% Train

The draft EIS indicates the Sydney Airport Land Transport Model (SALTM) was

used to predict the proportions of each transport mode used by air passengers to

and from the Airport (no rail trips) in 2031. It appears that adjustments were made

to these mode proportions to respond to the predicted capacity constraint of the

Airport Access Drive. The approach in determining these adjustments is unclear.

However, the results shown in Figure 7-6 and 7-7 of ‘WSA EIS GHD volume 4

appendix j surface transport and access’, contradicts the suggestion that the

Airport Access Drive forms a constraint in 2031. The figures show the Airport

Access Drive is not coloured pink or red, and therefore operates below capacity in

2031.

It is hence unclear why road link capacity was used to adjust transport mode

proportions.

The NSW Government is currently planning the SWRLe. At the time of the draft

EIS publication, no commitment to its construction had been made. As a result,

this draft EIS assumed no rail link would service the Airport by 2031. This lack of

rail service is likely to generate higher dependency on private vehicle usage and

possibly higher dependency on buses and shuttles. The draft EIS did not

specifically assess any predicted impacts of future Airport bus servicing on the

local bus network.

There is insufficient supporting information in the Draft EIS for Arup to comment

on the methodology used to assess air passenger public transport use in 2031.

Further modelling and benchmarking the public transportation use of the proposed

Airport against other airports of comparative size and function should be

considered.

Airport Employees Public Transportation Use

The draft EIS indicates the 2031 airport employee transport mode splits were

determined using journey to work (JTW) data for the existing Kingsford Smith

Airport.

As it was assumed that the airport in 2031 will not be serviced by rail, the rail

trips found in the JTW were apportioned to the other modes. The draft EIS then

compared these apportioned mode splits with JTW data for other employees in

adjacent areas to the proposed Airport site (Liverpool, Penrith, Camden, Fairfield,

Campbelltown, Blacktown and Holroyd).

The comparison suggested the JTW splits for the proposed Airport contained

higher private vehicle usage than the JTW splits for the adjacent areas. Hence its

use is considered conservative for the assessment of employee traffic impacts of

the proposed airport in 2031.


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3.2.2 Strategic Modelling Assumptions

To assess the changes in traffic movements as a result of construction and

operational traffic of the proposed Airport, this assessment used the STM3

transport model. Arup believes the STM3 is likely to contain the most up to date

assumptions and hence be well suited to capture the effects of the Airport at a

strategic level.

However, the following lists those assumptions that may be considered invalid or

lack supportive information:

a. Road Link Calibration and Validation – As stated in Appendix J of this draft

EIS, at the time of the assessment, the STM3 models were currently in

development by BTS. This assessment used the latest available version as the

basis for the draft EIS assessment. No model calibration or validation statistics

have been provided in this assessment, in particular for the existing major road

links in the vicinity of the Airport site. Arup appreciates the calibration

challenges of previous versions of the STM (STM and STM2). Poor

calibration of existing road links in base models can generate large errors in

the forecast performance of these road links in the future. Alternatively the

previously calibrated STM2 could have been used as the strategic model for

this assessment.

b. Model Road Toll Choice – The STM3 does not contain sophisticated toll

choice functionality. Arup notes that other large scale infrastructure EIS

assessments used a separate toll choice model to capture these effects with

greater confidence. Westconnex 1a and 1b used “…a toll choice model for

assigning road traffic to toll routes through the application of a toll choice

diversion model, known as a distributed value of time (VOT) multi-class

equilibrium assignment model” (Westconnex Stage 1B EIS). As stated in

Appendix J of this draft EIS, the use of a two-stage process to assign vehicles

to road links was used for the base year and future year road networks. The

second stage used a toll-choice assignment to reflect those vehicle drivers who

are willing to pay for tolls and those who are not. The methodology used to

model toll choice was not disclosed in the draft EIS. This is a potent a risk as

several major toll roads would provide access to the airport in the future

including:

M4

WestConnex

M7

c. Base year selection – This draft EIS indicated that 2011 was modelled as the

base year to represent existing conditions. Observed traffic data from 2011

was used to validate the model.

As stated in the assessment, the use of 2011 data does not include recent land use

developments in the region. This includes vehicles trips that are generated by the

BWSEA and SWGC today in 2015. As described in the assessment, some of the

road links in the region have grown by up to 2.8% per year between 2008 and

2014.


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Future years modelled in this assessment include the construction year (2021),

Stage 1 operation (2031) and longer term airport development year (2063) are all

forecast based on the 2011 base year calibration. There were no calibration and

validation results provided in the draft EIS. Furthermore, as described by BTS

“there may be some variation between (existing) modelled results and on the

ground results for the base year. For this reason the BTS recommends using STM

growth factors applied to known base year numbers, rather than the directly

predicted STM volumes” (BTS Technical Documentation, February 2011). This

suggests the importance of using correct ‘known’ base year data for all future

forecast modelling.

d. Future year selection – The draft EIS identified that 2031 was selected as the

year to represent Stage 1 Airport conditions.

As stated in the Draft Airport Plan – Western Sydney Airport (October 2015), the

Plan’s primary concern relates to ‘the Stage 1 Development… (which) would cater

for the predicted demand for the first five years of operation to around 2030’.

It also identifies that any airport development beyond this time (including a rail

link) will be ‘staged in line with demand’ and that ‘Developments after Stage 1

will be undertaken under the existing planning framework in Part 5 of the Act

(Airports Act 1996)’.

Arup understands the above to mean that prior to any long term development of

the airport being constructed, a major development plan (managed in accordance

with the Airports Act 1996) will be required with final approval provided by the

Minister of Infrastructure and Regional Development.

Hence, the use of 2031 as the year that represents Stage 1 of the Airport is

considered appropriate for this draft EIS.

e. Freight Traffic – The draft EIS considered future freight vehicle trips as a

result of the Airport. However, Arup notes these generated vehicle trips are

only related to the predicted tonnage of air cargo in 2031. It was identified this

would equate to approximately 9 and 13 heavy vehicle trips to/from the

Airport in the 2 hour AM and PM peaks respectively.

This heavy vehicle freight traffic is the only freight traffic predicted in this draft

EIS assessment. No allowance, assumption or testing of any other freight traffic

has been made in the assessment. Arup understands the proposed Airport is

predicted to serve freight operations (24 hours per day) that would generate vast

economic benefits to the region. The freight operations are predicted to unlock

economic benefits of Western Sydney’s growing population (SWGC) and

growing economy (BWSEA). Considering this strategic objective, and also that

this draft EIS assessment noted “the analysis excludes the traffic to and from the

proposed Airport generated by associated commercial development or freight

traffic for consumables”, there may be insufficient assumptions being made

regarding the likely freight traffic generation caused by the Airport.

Without a detailed terminal plan, it would be difficult to determine the heavy

vehicle traffic required to service the Airport with full confidence. However, as

stated in section 2.3 of the Draft Airport Plan – Western Sydney Airport (October


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2015), provision for specific types and quantity of zoned areas within the Airport

precinct is made. It also provides the potential uses within these zones. Hence, the

lack assumption regarding wider freight traffic generation and subsequent lack of

inclusion of such in this draft EIS is considered a risk.

It is not clear what assumptions were made regarding future freight movements in

the strategic modelling undertaken as part of the draft EIS. The Freight Movement

Model (FMM) has been used in other transport planning assessments. Like the

(STM3), the FMM is government owned and operated (by BTS). It predicts

freight movements by professional drivers that are not found explicitly in the

STM.

It should be noted, the FMM contains the Kingsford Smith Airport (both domestic

and international terminals) modelled and calibrated as a ‘special generator’. TDC

Heavy Vehicle Forecasts - February 2010 Release.

3.3 Discussion whether the conclusions reached in

the studies are valid

With consideration to Arup’s comments described in sections 3.1 and 3.2, Arup

notes some limitations within the Traffic and Transport sections of this

assessment, namely:

Potential gaps in and/or potential lack of supportive information for:

o Explicit future land use assumptions in the region of the Airport

o Potential land use within the Airport precinct that has not been

accounted for

o Airport related freight generation (above and beyond air cargo

tonnage)

Methodologies that measure traffic impacts that may not be considered

industry best practice, including:

o Intersection modelling not undertaken

Sections of analysis and commentary that may not be considered industry best

practice, including:

o Quantifiable values of road capacity (volume to capacity)

o Vehicle travel time comparisons on major road links, ‘with’ and

‘without’ the Airport not provided

o Intersection performance values, ‘with’ and ‘without’ the Airport,

are not provided (intersection modelling not undertaken)

o Intersection layouts (and subsequent potential land acquisition

impacts) required to accommodate future Airport traffic are not

provided or not described.


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Based on our review, these limitations could be considered significant. Further

information would need to be provided to enable Arup to reach a firm opinion as

to whether the conclusions reached in the study are valid. Until these comments

are addressed or further information supplied, Arup is unable to comment on the

validity of the conclusions reached in this draft EIS.

3.4 Review of proposed mitigation and management

measures

Regarding the traffic impacts caused by construction activities, industry standards

and best practice allow EIS documents to refer to the requirement of a

Construction Traffic Management Plan (CTMP) as part of a Construction

Environment Management Plan (CEMP) to capture and mitigate specific

construction disruptions to the community. This assessment nominates these

requirements. Arup believes this approach is fit for purpose.

Regarding the traffic impacts caused by the operation of Stage 1 of the Airport,

this assessment concluded that the Western Sydney Infrastructure Plan will

provide sufficient road capacity that will accommodate airport related traffic.

Nonetheless, this assessment also mentions that mitigation and management

measures that will reduce any other impacts will be delivered via a Ground

Transport Plan (as part of detailed design). Subject to the comments raised by

Arup in the rest of this peer review, this approach could be considered in

accordance with industry standards.


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Page 18

3.5 The level of uncertainty over impacts and the

environmental risks

The following matrix tabulates what Arup believes to be the level of uncertainty

to the traffic and transport impacts caused by the Airport.

Level of Uncertainty

Issu

e

Low Medium High Unknown

Assumption gaps

+

Lack of supportive information

Explicit future land use in region

and subsequent traffic generation X

Potential land use within the

Airport precinct subsequent traffic

generation

X

Freight generation (outside of air

cargo) X

Assessment Methodology

Intersection performance X

Analysis and Commentary

Explicit volume to capacity ratios of

midblock road links X

Vehicle travel time comparisons X

Public transport operations X

Intersection layout descriptions X


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4 Detailed Findings: Long Term development

Arup understands that the assessment of the long term development of the

Western Sydney Airport should be viewed as ‘preliminary consideration’. Prior to

the long term development of the airport being constructed, a major development

plan (managed in accordance with the Commonwealth Airports Act 1996) will be

required with final approval provided by the Minister of Infrastructure and

Regional Development.

4.1 Approach of Airport long term development

assessment

The predicted traffic impacts of the long term development of the Western Sydney

Airport largely followed the Stage 1 assessment, including:

Similar Airport vehicle traffic generation

Air Passengers (private vehicles, taxis and buses)

Airport Employees (private vehicles, taxis and buses)

Air Cargo Tonnage (freight vehicles)

Similar road network modelling assessment (traffic impacts)

Midblock capacity assessment (STM3)

Similar presentation of analysis, results and commentary

However, the key difference between the Stage 1 and long term development

assessment are:

Road network configuration

Introduction of Castlereagh Highway connection to the M7

Introduction of passenger rail link

South West Rail Link Extension (SWRLe)

North and south connection of the SWRLe to St Marys and

Narellan respectively

4.2 Potential ‘gaps’ of long term development

assessment relative to a conventional EIS

assessment

When identifying the potential gaps in the long term airport development impact

assessment, Arup broadly considered the following:

Arup’s comments regarding the limitations of the Stage 1 assessment

described in sections 3.1 to 3.4,


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The long term development impact assessment largely follows the Stage 1

assessment

Prior to the long term development of the airport being constructed, a major

development plan (managed in accordance with the Commonwealth Airports

Act 1996) will be required with final approval provided by the Minister of

Infrastructure and Regional Development.

The following are specific gaps or areas of concern that Arup believes are related

to the long term development impact assessment:

The draft EIS states that the Airport Access Drive (from M12) is predicted to

fail in 2050

o Failure of the Airport Access Drive has been defined as when the

midblock reaches LoS of D. This corresponds to a midblock

capacity of 1,700 vehicles per hour per lane.

o When considering the environment of an airport access road (multi

decision points, merging and weaving effects, passenger drop offs

effects), Arup notes the 1,700 vehicles per hour per lane capacity is

likely to be overestimated. Nonetheless without a detailed layout

plan of the internal road network, it is difficult to comment on the

appropriateness or the likely effects of this capacity assumption.

o Arup inferred (via the graphical results provided) the inbound or

outbound vehicle movements on the Airport Access Road will be

over capacity for 15 hours out of 24 hours per day

o The road link capacity is reached approximately 13 years before

the long term airport development impact assessment scenario year

(2063)

The Northern Road, M7, Elizabeth Drive, Mamre Road, Luddenham Drive

reach capacity with the Airport in 2063. The assessment has not provided any

strategic measures to mitigate these constraints.

Passenger Rail Link Provision (SWRLe)

o Insufficient information has been provided to determine how air

passenger demand would access and egress the Airport beyond

2050 (when the Airport Access Road reaches capacity). The WSA

EIS GHD volume 4 appendix j surface transport and access does

identify:

“…… that this forecast level (access road failure) is

predicted to be achieved in based on current airport

passenger volumes 2050 and investment in rail

infrastructure would be required beyond this point… to

enable the Airport to reach the desired 82 MAP”

“the modelling undertaken for the concept plan requires the

capacity of the proposed access road network to be a


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Page 21

constraint, the mode split proportions are required to be an

input….(and) are shown in Table 9.3”

“the mode split for car modes was modified down based on

the capacity of a potential staff car park when the access

road reaches its nominal capacity”

o Arup has hence inferred (from above) that a large proportion of air

passenger and airport staff trips will be required to shift from

vehicles to rail beyond 2050. However:

The STM3 does not account for rail capacity constraints

Passengers are therefore not deterred from catching trains

even if they are crowded

The graphs contained within the long term airport

development assessment suggest train arrival and departure

demands of approximately 2,000 trips per hour for many

hours of the day. No information has been provided as to

assess what impact this would have on the Sydney Rail

Network.

STM3 modelling only considered the morning peak public

transportation network only.

Arup understands the long term airport development assessment to be in a

‘preliminary consideration’ phase and may not require the level of detail of an EIS

assessment. Hence the issues or ‘gaps’ noted above should be viewed in this

context.

Arup recommends a future airport long term development assessment could be

undertaken with additional rigour which could explicitly address the issues

relating to detailed passenger rail planning and detailed road network planning.

4.3 Key risks and implications as a result of the gaps

As Arup understands the long term airport development assessment to be in a

‘preliminary consideration’ phase it may not require the level of detail of an EIS

assessment. As a result, the implications of the aforementioned gaps are less

severe. This is subject to a commencement of further investigations.

4.4 Effectiveness of the assessment in setting a

framework for further assessment.

The assessment of the long term airport development impact has mentioned

limitations within the methodology and/or limitations in available information

required for the assessment. These are:

Committed road network beyond 2041 (to 2063)

Commitments to the nature of the SWRLe.


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Arup hence believes the assessment has eluded to further studies that may be

required to assess the long term airport development and hence has effectively

provided some of the framework required for further assessment.


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5 Summary of key impacts and opportunities

5.1 Construction

The following describes the predicted construction traffic impacts caused by the

Airport as described in the draft EIS:

The traffic impacts of construction of the Airport on the local road network is

predicted to be relatively low. The proponent predicts the local road

performance and operations ‘with’ and ‘without’ construction traffic to remain

relatively stable.

With regard to above, it is difficult for Arup to confirm the validity of these

impacts with confidence. Arup has identified further information that could be

provided to quantify the potential impacts, including:




5.2 Stage 1

The following describes the predicted traffic impacts caused by Stage 1 of the

Airport as described in the draft EIS:

The traffic impacts caused by Stage 1 of the Airport is predicted to be

relatively low. The draft EIS states “the substantial package of road

improvements proposed as part of the WSIP, in addition to those identified in

the BWSEA and SWGC, would have sufficient capacity to cater for the

expected airport passenger and employee traffic demand in 2031” (WSA EIS

GHD volume 4 appendix j surface transport and access). With consideration to

the methodology used, the draft EIS states the future road network is able to

accommodate the predicted Airport traffic demand.

With regard to above, it is difficult for Arup to confirm the validity of these

impacts with confidence. Arup has identified further information that could be

provided to quantify the potential impacts, including:

Freight traffic generation within the Airport precinct (outside of air cargo)

Private vehicle traffic generation from land uses within the Airport precinct

(outside of air passengers)





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5.3 Long term Airport development

The following describes the predicted traffic impacts caused by the long term

development of the Airport as described in the draft EIS:

The traffic impacts caused by the Airport is predicted to be significant. The

Airport Access Drive from the M12 is predicted to fail in 2050. This is

approximately 13 years before the ultimate long term airport development

year (2063).

The traffic impacts also effect the wider road network with significant

congestion predicted on key road links in 2063. The assessment acknowledges

this is a result of significant background growth in conjunction with unknown

road infrastructure commitments past 2041.

The Airport also impacts wider transport modes. The assessment suggests

additional rail link capacity (above and beyond the SWRLe) would be

required to accommodate both the Airport trips and background growth trips

by 2063.

For the purposes of the Peer Review, Arup was not privy to the specific

requirements of the draft EIS. Arup recommends detailed transport network

planning including road and rail network planning.


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6 Peer Reviewers Qualifications

Sam Gray

Sam is a Senior Traffic Engineer based in Sydney with extensive experience in

the development, design and management of transport planning and road design

projects. Sam is a specialist in planning and operational assessments of road

networks, motorways and public transportation.

Specifically, Sam has vast experience in the application of land used changes on

motorway and surface road networks. His has expertise working with forecasting

demands and operational flows to suitably assess road and motorway projects. His

strategic and operational assessments include road construction staging, interim

network staging and ultimate layouts. He completes design options analysis,

traffic impacts and environmental impacts to validate a wide variety of projects.

Sam also understands the strategic elements of road planning and the relationship

between modal shifts which is evidenced by his involvement on related projects

that incorporate wider transportation solutions. His qualities and experience allow

him to identify project hurdles early and he has shown that he can overcome these

project hurdles by relaying the critical information pieces above and below first

hand. This practise allows for quality decisions making across the project,

manages expectations of possible project changes, and ultimately allows for

timely delivery of quality project outcomes.

Project Experience

NorthConnex (M1-M2) EIS Approvals, Sydney

Mona Vale Road REF Traffic and Transport Study, Sydney

North West Rail Link EIS Approvals, Sydney

WestConnex Stage 3 Road Operations Assessment, Sydney

WestConnex Full Scheme Business Case, Sydney

WestConnex Alignment and Interchange Assessment, Sydney

Northern Beaches Hospital Road Network Assessment, Sydney

Old Wallgrove Road Upgrade Design Construction Staging, Sydney

Camden Valley Way Road Upgrade Design, Sydney

Edmondson Park Road Network Assessment, Sydney

Inner Newcastle Road Network Study and Concept Designs, Newcastle


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Page 26

Peter Dunn

Peter is a transport planner specialising in strategic transport planning, economic

evaluation, demand forecasting, and design of transport infrastructure. He has

extensive international experience in major transportation projects. As an

Associate Principal, Peter is responsible for the project management of transport

related work undertaken in Australia and New Zealand. Peter has a firm

understanding of transport issues as they relate to the needs of different cities,

through being responsible for significant transport planning studies in Australia,

New Zealand, England, Ireland and Hong Kong. He is experienced in the

application of analytical techniques to assess and provide solutions to complex

transport issues. His design experience includes numerous road planning and

intersection design studies.

Project Experience

Public Transport Project Model Audit, Sydney

NSW Long Term Transport Master Plan: Transport for New South Wales

Auckland Public Transport Model: Review of mode specific constant

Wellington Strategic Transport Model Peer Review, New Zealand.

AMETI Model Peer Review, Auckland New Zealand

Wellington Public Transport Model Review

Sydney Metro Demand Analysis Advisor, New South Wales

Sydenham to Bankstown Corridor Study

Central to Eveleigh Transport Study

Canberra Light Rail Master Plan


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Andrew Hulse

Andrew is an Associate Principal in the Transport Planning division of Arup,

Sydney. He provides transport planning advice and design input on a range of

major development projects. Andrew has worked with Arup for 30 years in a

number of the Arup Australian offices, in London for a two year secondment and

Hong Kong and Singapore on specific projects.

He has particular skills in the areas of traffic management, bicycle planning,

traffic calming, hospital parking demand and town centre traffic and parking

design. Many of these projects have involved public consultation and Andrew has

acted as an expert witness on a range of project types.

Andrew provides transport advice on multi-disciplinary projects working closely

with planners and architects on projects such as CBD office developments, land

rezoning studies and site master planning. He provides patronage assessment,

interchange design and route assessment for public transport infrastructure

projects, and undertakes traffic assessment for major road projects.

Project Experience

Melbourne Airport Southern Precinct Project

Brisbane Domestic Terminal (Precinct) Expansion Projects, QLD, Australia

Sydney Airport International Terminal, Ground Access Project

Newcastle Airport Car Park

Canberra Airport Master Plan

FIFA World Cup Transport Strategy

Sydney International Convention and Exhibition Centre Peer Review

Barangaroo Development

TfNSW Transport Access Program

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